Collapse All

August 16, 2021

Introduction

The E-Rate Central News for the Week is prepared by E-Rate Central. E-Rate Central specializes in providing consulting, compliance, and forms processing services to E-rate applicants. To learn more about our services, please contact us by phone (516-801-7804), fax (516-801-7814), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

Wave 18 for FY 2021 was released on Thursday, August 12th, for a total of $82.9 million.  Cumulative commitments are $1.89 billion.  Nationwide, USAC has now funded 90% of the FY 2021 applications representing 64% of the requested funding.

The 2021-2022 application window for the Emergency Connectivity Fund (“ECF”) closed last Friday, August 13th.  If USAC matches its application processing rate with the success it achieved for regular FY 2021 applications earlier this spring, we would expect the first wave of ECF funding commitment decision letters (“FCDLs”) in less than four weeks.  More broadly, the FCC’s target is to have USAC issue FCDLs for 50% of the workable applications within 60 days and 70% within 100 days.

Currently, there is little data available on the total amount of ECF funding requested during this initial window.  USAC is currently working on providing Open Data access to ECF information with a mandate from the FCC to have it available no later than January 29th — and hopefully well before that.  In the meantime, lack of data is a challenge for all stakeholders — applicants, service providers, USAC and the FCC — seeking to gauge the real ECF demand.

In the interim, the best we have is survey data.  Based on our analysis of a sample of applications filed by 330 public school applicants representing over 1.65 million students, we noted the following:

  • The average applicant in our sample filed for $300 per student.  Extrapolating that unit request to the national student base would push total requests above the $7 billion program cap that would require an allocation of funds to needy applicants.  Fortunately, a sizable number of schools and libraries did not apply.
  • Additionally, we should note that our sample was skewed by a $430 per student request from one very large school district.  The median per student request in our survey was about $245.
  • Per student requests in excess of $400 appeared to include a large number of connected devices (e.g., Chromebooks) and services for a large proportion of the applicant student base, either students (and staff) who had not been provided with home services before or who had been using out-of-date equipment deemed no longer sufficient for remote learning.
  • Substantial funding was requested for hotspots and for increased numbers of students particularly in expanding charter schools.
  • Funding over $3,000 per student was requested by a few applicants planning network construction in unserved areas.

We noticed a relatively large number of incomplete applications as of the window deadline.  As may become clearer later this week, some of these applicants may be intending to submit late-filed applications in the hopes that the FCC, as it has with traditional E-rate applications, waives the deadline for applications filed within 14 days.  As we indicated in our newsletter of August 9th, the FCC has not yet formally indicated its waiver policy for late-filed applications.  A final FCC decision may depend on total demand estimates for in-window filings.  Out-of-window applicants planning to file waivers should review USAC’s recently posted instructions for submitting ECF window waiver requests (importantly reminding filers that the ECF waiver deadline is 30 days, not the traditional 60 days).

Upcoming E-Rate Dates:

August 19     Form 486 deadline for FY 2020 covering funding committed in Wave 52.  More generally, the Form 486 deadline is 120 days from the FCDL date or the service start date (typically July 1st), whichever is later.  Upcoming Form 486 deadlines are:
Wave 53            09/02/2021
Wave 54            09/09/2021

Last week, approaching the ECF application window deadline, USAC released its regular Tuesday newsletter plus three other comparable advisory emails, namely: