News of the Week

E-Rate for FY 2023:

USAC issued Wave 39 for FY 2023 on Thursday, January 18th, for $16.5 million.  Total funding is now $2.55 billion.  At this point, USAC has funded 97.2% of the originally submitted applications representing 90.5% of the dollars requested.

ECF for 2021-2023:

Total commitments for all three ECF windows are $6.45 billion. 

E-Rate for FY 2024:

The Form 471 filing window for FY 2024 opened last Wednesday and will close on Wednesday, March 27th, at 11:59 p.m. EDT (see USAC Special Edition News Brief referenced below).

Initial comments on the FCC's Notice of Proposed Rulemaking ("NPRM") (FCC 23-91) on the eligibility of hotspot loans (see our newsletter November 13th) were due last Tuesday.  Most comments fully supported the FCC's proposal to make remote, off-campus, hotspots for students and library patrons eligible for E-rate support.  Links to a broad sampling of the comments received, both pro and con, are provided below.

For an FCC that has been reluctant to provide additional E-rate funding for cybersecurity, only now proposing funding outside of E-rate for a three-year cybersecurity pilot, the most important issue we see is how to fund both new E-rate programs, hotspots and school bus Wi-Fi.  With regard to hotspots, most of the comments ducked this issue aside from simply discussing possible per student caps.  The few comments addressing funding limits included:

• Funds For Learning, extrapolating from ECF experience, estimated an annual E-rate cost of close to $200 million.  With the likely demise of the ACP program, we believe that estimate may be conservative.
• EdLiNC and SECA, assuming a cap on annual hotspot funding, discussed allocating limited funding by discount rate.  The mechanism to do this would work like Internal Connections funding was rationed in the early Priority Two days with funding first made available to 90% discount applicants, then to progressively lower discount applicants if funds remained available.  This might require setting up hotspots as a new Category 3.  Under this scheme, some applicants would get hotspot funding, some might not — and many might not know until late in the funding cycle.
• E-Rate Central's own proposal advocated funding for a specific number of available hotspots and service packages for all schools and libraries based on a combination of size and discount rates.

Funding and its allocation are a critical issue that needs to be addressed.  We encourage interested parties to read the comments with these issues in mind and to comment appropriately during the reply period.  Reply comments on the hotspot NPRM are due January 29th.

Pro Hotspot Comments:
American Library Association ("ALA")
Council of the Great City Schools
Dallas ISD
Education & Libraries Networks Coalition ("EdLiNC")
E-Rate Central
EveryLibrary Institute
Funds For Learning
Oakland Undivided & Oakland Unified School District
Schools, Health & Libraries Broadband Coalition ("SHLB")
    and The Open Technology Institute at New America
State E-Rate Coordinators' Alliance ("SECA")
Wisconsin Department of Public Instruction

Con Hotspot Comments:
Advocates for the EMS Disabled
America's Communications Association ("ACA")
NCTA – The Internet & Television Association

Upcoming Dates:

USAC's E-Rate Special Edition News Brief dated January 17, 2024, announced the opening of the FY 2024 Form 471 application window and provided brief advice on:

• Gaining access to EPC for first-time filers.
• Reviewing the Eligible Services List ("ESL").
• Filing a Form 470.
• Filing a Form 471.

The News Brief points to upcoming training opportunities including a session this coming Thursday, January 25th, on service provider selection and the Form 471 (register here).

Applying for School Bus Wi-Fi:

Last week's News Brief also makes a few references to filing for school bus Wi-Fi equipment and services by:

• Referring back to the Form 470 guidance in USAC's December 15, 2023 E-Rate News Brief.
• Noting that the Form 471 bulk upload template cannot be used for Wi-Fi on buses.
• Highlighting last week's Eligible Services E-Rate Question & Answer (Q&A) session that focused on bus Wi-Fi issues.  A recording of that session is expected to be made available online shortly (check for posting).

Based on our own Form 471 applications being filed, here are a few hints:

In the Product and Service Details section, indicate Wireless School Bus Service as the function and specify Wireless data service as the Type of Connection.

Indicate the Number of Buses Being Serviced in the field provided and in the Funding Request Narrative.  If service is being requested for buses that had previously been equipped with Wi-Fi equipment, either independently or with ECF funding, we suggest adding that information in the narrative section as well to help explain why more wireless subscriptions are being requested than wireless routers.

The recipient of service section for each bus Wi-Fi FRN should include all schools to be served by the Wi-Fi equipped buses.