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April 14, 2014

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.

The FY 2014 application window closed on Wednesday, March 26th.  Funding waves are expected to begin in May.

Wave 47 for FY 2013 will be released on Wednesday, April 16, 2014, for $2.6 million.  Funding for FY 2013 is available for Priority 1 services only.  Priority 2 is being denied at all discount levels.  Cumulative funding for FY 2013 is $2.04 billion.

A very small wave for FY 2011 (Wave 112 for less than $16 thousand) is scheduled for Tuesday, April 15th.

Initial comments on the FCC’s Public Notice on E-rate modernization (DA 14-308) were due last Monday.  As of the end of last week, approximately 700 comments had been filed.  Eliminating a substantial number of apparent duplicates (close to a hundred filed by one individual), the filing total was closer to 550.  Of these, roughly 150 were more than simple one-pagers, usually with some substance.

To search for all filed comments in this proceeding, use the search function in the FCC’s Electronic Comment Filing System.  Enter “13-184” in the Proceeding Number field, and click the “Search for Comments” button near the bottom of the screen.

Those wishing to explore a somewhat more manageable list of comments may be interested in the following:

In reviewing these comments, we believe it is important to focus on the following four key elements of the E-rate modernization proposals put forth by the FCC:

  1. Replacing the current two-priority system with a new two-category system, each separately funded.
  2. Within each category, emphasizing broadband services and phasing out support for voice and other "legacy" services.
  3. Considering several ways to allocate funding for broadband internal connections.
  4. Providing an additional $2 billion in E-rate funding for FY 2015 and FY 2016.

Based on a preliminary review of the initial comments filed in this proceeding, it appears that there is widespread agreement on basic issues and goals, but equally widespread disagreement on the detailed nature or timing of the changes required.  In particular:

  1. Almost all agree with the Commission’s focus on broadband, and that support for broadband services must extend all the way to the classroom.
    1. Many agree that it would be advantageous to treat broadband internal connections as a separately funded category rather than as a lower priority.
    2. There appears to be no consensus as to which of the three alternative proposals for allocating internal broadband funding is best.
  2. All agree that E-rate funding is limited, and that, even with the addition of $2 billion over the next two years, a long-term solution will require some combination of additional funding, the narrowing of eligible products and services, and/or cuts in discount rates.
  3. There is a general acceptance of the need to phase out eligibility of voice and other “legacy” services, but the extent and timing of the phase-out(s) remain controversial.

Reply comments in this proceeding are due April 21, 2014.

Form 486 Deadlines:

Typically, a Form 486 must be filed no later than 120 days from FCDL issuance or the start of service, whichever is later.  Assuming services started July 1, 2013, the deadlines for FY 2013 funding waves 1-30 have already passed.  The Form 486 deadlines for the remainder of April are:

            Wave 31      04/17/2014
            Wave 32      04/28/2014

Since the pace of FY 2013 funding is slowing, we plan to halt our weekly reminders of Form 486 deadlines.

The SLD News Brief for April 11, 2014 discusses a number of aspects of service eligibility that will be examined by PIA as it reviews Item 21 attachments.  Topics covered include:

  • Conditionally eligible products and services
  • Partially eligible products and services
  • Ineligible products and services
  • The cost of eligible products and services