Upcoming 2017 E-Rate Deadlines:
| August 15 |
USAC webinar to provide E-rate Training for Beginners. Note also that last week’s USAC webinar providing Service Provider Training Highlights (from the July 25th session in Dallas) was recorded and is available online. |
| August 18 |
Form 486 deadline for FY 2016 funding committed in Wave 43. More generally, the Form 486 deadline is 120 days from the FCDL date or the service start date (often July 1st), whichever is later. This means that Form 486 deadlines for funding commitments received in later waves will follow at roughly one week intervals, including the following deadlines:
Wave 44 08/25/2017
Wave 45 09/01/2017
Wave 46 09/07/2017
Wave 47 09/19/2017
Applicants missing these (or earlier) deadlines should watch carefully for “Form 486 Urgent Reminder Letters” (actually emails directing the applicants to EPC News Feed items). The Reminders will afford applicants with 15-day extensions from the date of the emails to submit their Form 486s without penalty.
The earliest Form 486 deadline for FY 2017 will be Monday, October 30th.
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| Sept. 30 |
Service delivery deadline for the receipt of non-recurring services (i.e., installation or other one-time charges) for FY 2016. Requests to extend the service delivery deadline, if needed, must be made on or before this date. |
| October 10 |
USAC’s first annual fall applicant training session in Washington DC will be limited to state E-rate coordinators and other “executive or senior” managers with E-rate responsibilities. Training sessions for other attendees are planned in Charlotte, Minneapolis, and San Diego (dates to be announced). In all, USAC’s traditional fall training schedule has been cut in half, presumably as a cost cutting measure and in favor of a broader range of webinars. |
ESL Reply Comments:
Reply comments on the FCC’s proposed Eligible Services List (“ESL) for FY 2018 were due last week. There was broad consensus from a number of school districts, AT&T, and the State E-Rate Coordinators’ Alliance (“SECA”), supporting initial comments from Kellogg & Sovereign Consulting, on the need to address eligibility and/or funding flexibility for transitional changes in telecommunications services (either bandwidth upgrades or new carriers).
SECA’s reply comments also discussed:
- The importance of additional clarity on the treatment of Category 1 equipment needed to make broadband services functional.
- The need, at least as an option, of treating connections between multiple schools on a single campus as Category 2. Under current rules, such connections must be treated as Category 1, meaning that applicants planning to link the schools with self-provisioned fiber must bid for, and compare, private fiber with carrier-provided lit fiber and transport only services. (Note: An alternative would be to waive the fiber comparison requirement for on-campus Category 1 services.)
- The rationale for permitting the funding of multiple Internet providers to ensure adequate and reliable Internet access services.
Reply comments by T-Mobile USA asked the FCC to update ESL guidance on the cost-effectiveness of mobile wireless services as compared with fixed Wi-Fi systems.
Transfer of USF Funds to the U.S. Treasury:
USAC announced that it is coordinating with the FCC to develop a plan to transfer the funds from the Universal Service Fund (“USF”), currently held at a third-party banking institution, to the U.S. Department of Treasury. Exactly how this change might affect E-rate funds may depend upon the transition plan scheduled for release in November. The transfer itself is planned to be completed in 2018.
USAC’s Fund Size Projections for 4Q17:
USAC released its Universal Service Fund Size Projections for the Fourth Quarter of 2017. This latest quarterly projection shows a drop in the available E-rate funds from a total of $1.264 billion as of the third quarter to $342 million in the fourth quarter.
In May, just two days before USAC released Wave 1 for FY 2017, the FCC issued an order (DA 17-507) indicating the availability of $1.2 billion in unused funds and directing USAC to use that funding (and any additional funds as needed) to fully fund for all valid Category 1 and Category 2 requests. The 3Q17-to-4Q17 decline reflects the carry-forward (or “roll-over”) of the $1.2 billion into FY 2017, presumably offset by additional reserve identified during the fourth quarter.