USAC’s guidance on Form 470 requests for bundled Internet access and transport services was changed last week during the first of USAC’s fall training workshops in Washington, DC, — apparently at the direction of the FCC. The change was not included in any of the training slides, but became apparent during a Q&A session. It is not yet reflected in any written USAC material.
Here is the current Form 470 guidance on bundled Internet service requests as we now understand it:
- If you are seeking Internet access service, and the Internet service provider (“ISP”) will be providing a non-fiber connection (e.g., DSL) to deliver that Internet service, the only Form 470 drop-down menu option required is “Internet Access and Transport Bundled.”
- If, however, the ISP will be providing a fiber connection to deliver Internet access (as is often required for higher-speeds), two Form 470 drop-down options must be selected — “Internet Access and Transport Bundled” and “Leased Lit Fiber.”
- If you don’t care what type of connection is provided, but wish to merely specify a minimum Internet speed (or speed range), you should also use both the “Internet Access and Transport Bundled” and “Leased Lit Fiber” options. Without including the “Leased Lit Fiber” option, any subsequent request for a bundled fiber-based Internet service will apparently be denied.
Prior to this change, USAC’s Form 470 guidance for bundled, fiber-based, Internet access service required applicants to include three drop-down options — “Internet Access and Transport Bundled,” “Leased Lit Fiber,” and “Internet Access: ISP Service Only.” This unintuitive guidance, of which many applicants were unaware, traces back to the August 26th introduction of new Category 1 drop-down options in EPC’s Form 470 — ironically characterized as “simplified” (see USAC’s Special Edition News Brief of August 22nd ). The updated guidance, reducing the number of required drop-down options from three to two, will still be a source of confusion. Absent official USAC guidance reducing the required dropdown from three to two, we encourage applicants to continue to use the three-option approach.
Hopefully, USAC will provide written clarification shortly and will proactively reach out to any applicants having filed incomplete Form 470s for bundled Internet services since August 26th. Applicants having filed Form 470s prior to August 26th should not be affected by the new — and changing — guidance.