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November 14, 2022

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 (516-801-7810), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

E-Rate for FY 2022:

Wave 30 for FY 2022 was issued on Thursday, November 10th, for $19.8 million.  Cumulative commitments to date are $2.68 billion.  Nationwide, USAC has funded 97.0% of the FY 2022 applications representing 88.8% of the requested funding.

ECF for 2021-2023:

Total commitments for all three ECF windows are $6.28 billion.  Total disbursements as of last Friday were $2.18 billion.

For many applicants, the individuals designated as the Account Administrators in EPC play little role in the ongoing E-rate process.  The administrators may only access EPC when users need to be added or deleted or when permissions need to be set or changed.  Unfortunately, when such changes need to be made, we often find that the Account Administrators of record are no longer in a position to do so.  Updating the Account Administrators in those situations takes extra time and effort by others.

We raise this issue now, not only because we are in the midst of the E-rate administrative window, but because USAC is about to transition the BEAR process into EPC.  Once this transition occurs — expected in December — individuals currently authorized within the existing BEAR processing system will be able to create and/or certify BEARs only within EPC.  Post-transition, EPC is expected to have separate fields for “472 Permission” as shown below.

E-rate BEAR System Changes and EPC Account Administrator Updates

We understand that USAC will attempt to carry-forward existing BEAR system users into EPC to give them equivalent permissions but that is clearly something that applicants will want to check.  Existing BEAR system users may have to be added into EPC as users and be assigned BEAR permissions.  This can only be done by the applicants’ EPC Account Administrators — hence our suggestion that all applicants confirm and/or update their Account Administrator designations now.

In many of the most rural areas of the country, E-rate can help bring down school and library costs for internet access, but only to the extent that local infrastructures can support high-speed broadband services.  Broadband in unserved or under-served areas remains expensive or unavailable altogether.  COVID-era legislation, including the Infrastructure Act, is set to provide billions of dollars designed to close the nation’s digital divide, but only to the extent that those funds are properly targeted to the most deserving states.  As might be expected, this is leading to major controversies being played out in broadband mapping data.

At the heart of the controversy is the FCC’s Fixed Broadband Deployment map that many states and other organizations believe relies too heavily on carrier-provided reporting and, as such, dramatically overstates existing coverage.  One alternative source of data is the National Broadband Map developed by BroadbandNow.  Nationwide the two maps show differences of the following magnitude:

FCC Broadband Mapping Controversy

Later this week, the FCC plans to “unveil a pre-production draft of new broadband maps” that may resolve some of the differences in coverage but is unlikely to quell the controversy.

One outgrowth of this controversy is a growing sense of competition between states for the allocation of federal broadband funding.  The best prepared states are those that have already begun investing in broadband and that have developed their own mapping programs.

Upcoming Dates:

November 18     The Form 486 deadline for FY 2022 Wave 14.  More generally, the Form 486 deadline is 120 days from the FCDL date or from the service start date (typically July 1st), whichever is later.  Upcoming Form 486 deadlines are:
Wave 15                      11/25/2022
Wave 16                      12/02/2022
Wave 17                      12/09/2022
Wave 18                      12/16/2022
Wave 19                      12/23/2022
Wave 20                      12/30/2022