Out-of-the-Window Applications for FY 2017:
Applicants who missed last Thursday’s close of the FY 2017 Form 471 application window can still file applications through EPC. Late applications will be considered Out-of-the-Window and will be denied by USAC — unless such applicants file successful waiver requests with the FCC. Recent precedent — if followed by the new Republican-dominated FCC — suggests that the FCC will automatically approve waivers of the filing window deadline for applications filed within two weeks of the original window close (i.e., by May 25th).
Interestingly, due to another apparent bug in the EPC system, at least a few applicants received the following conflicting Task messages, first confirming successful filing of their Form 471s by last Thursday’s deadline, then erroneously indicating that their applications were filed after the close of the window.
Late-filing applicants, who did file Out-of-the-Window applications, may legitimately receive the same message. In these cases, the instructions for filing an FCC waiver may prove useful.
Special Construction Extensions for FY 2016:
FCC rules on special construction for leased dark fiber or self-provisioned networks require those systems to be completed within the funding year. For FY 2016, unless specifically extended, this means that each link must be lit by June 30, 2017. Note that this completion requirement does not include the three-month grace period (to September 30th) afforded to Internal Construction and other non-recurring services.
A one-year extension for the completion of fiber special construction projects may be requested from USAC if the construction was “unavoidably delayed” due, for example, to late funding commitments or weather problems. Note that there are no automatic extensions due to funding dates; each applicant requiring an extension must submit a request to USAC by June 30th. Instructions for requesting an extension are provided in USAC’s News Brief of April 21st.
USAC has already begun approving special construction extensions. The approvals are in letter format (see example) emailed directly to the applicants. Given the importance of timely approvals, USAC is currently handling extension requests manually, i.e., not through EPC nor the legacy system. As a result:
- There is no system in place to notify the associated service providers of approved extensions. This responsibility falls on the applicants.
- There is no online record of approved extensions. We would expect that such extensions may ultimately be included in the FRN Extension Table for FY 2016, but this too may require manual intervention.