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May 12, 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.

USAC announced it will release FY 2014 Funding Commitment Decision Letters (FCDLs) for  Wave 1 on Thursday, May 15, 2014 to school and library applicants. This first wave will have more than 14,600 letters committing over $607 million, of which $450 million is for broadband connectivity. The FCDLs will notify applicants of funding commitments for Priority One services (Telecommunications Services and Internet Access) for all discount bands from 20% to 90%. USAC will issue waves of funding decisions each week until all applications have been processed.

When the FCDL is received, applicants must file the Form 486. The SLD has updated the online form to work with FY 2014 data and will also be available for online filing starting Thursday, May 15 (see section “E-RateUpdates and Reminders” below).

For FY 2013 USAC will release Wave 51 Funding Commitment Decision Letters (FCDLs) on May 14. This wave includes commitments for approved Priority One requests at all discount levels. As of May 12, FY2013 commitments total over $2.05 billion.

FCC Chairman Tom Wheeler began last Tuesday’s E-Rate Modernization Workshop with praise for the E-rate program, but he also stated that the program needs modernization to focus on high-speed broadband with service to students and patrons (not just to the building). While efficiency improvements are still needed, he reported that the FCC and USAC have completed an overhaul of the administrative process, prioritizing FY 2014 applications to move broadband services more quickly. Chairman Wheeler said that the first FY 2014 wave would be going out for half a billion dollars (USAC subsequently announced a total of over $607 million). There will be six times more high-speed broadband commitments in this wave than in the first wave last year.

Commissioner Ajit Pai agreed with the Chairman’s remarks, providing an example of the power of high-speed broadband to teach students that he had observed in a classroom in the San Fernando Valley: the teacher asked the students to use their iPads to search for the term “tessellation” in Google images and to describe what they saw. The students did that and then discussed why Muslims integrate tessellation in their art. Rather than simply being told about tessellation, the students were able to research it themselves and then understand its use in art. Pai expressed confidence that real E-rate reform will be achieved this year with the goals being: a student focus, easier navigation, a fairer distribution of funds to rural areas, and more transparency in how the funds are being used.

Commissioner Jessica Rosenworcel pointed out that E-rate is the largest educational technology program in the nation. She noted three key objectives for reform: a focus on speed (100 Mbps in the short term and 1 Gbps in the long term); streamlining of the application process; spending smartly by eliminating, for example, paging and voice service; and spending more in total. She acknowledged that she and her FCC colleagues needed to have more discussion about increasing the level of E-rate funding. She also endorsed the concept of multi-year applications to allow long-term planning and to cut in half the administrative cost borne by USAC and program participants.

Richard Culatta, Director of the Office of Educational Technology at the US Department of Education, emphasized that the E-rate program’s reform is not about broadband itself. He stressed that the broadband initiative is a means to reach educational goals and that any sentence about broadband should conclude with the educational purpose the broadband enables.

The first panel of speakers included two school district superintendents, a library system executive director (who was Librarian of the Year), and the Executive Director of the National Indian Education Association (“NIEA”). FCC staff asked the first three panelists to describe how they use high-speed broadband to improve the services they provide and how they obtain resources beyond E-rate. They acknowledged that budget decisions are difficult, underscoring the need to inform the community-at-large how technology enables learning and the need to economize, perhaps through consortia. The NIEA representative said there are few E-rate success stories in Indian country and asked the Commission to remember their special needs as they pursue reform. With a Commission goal of 99% connectivity, the Indian nations are concerned that their tribes will be the one percent that lacks connectivity.

The second larger panel of experts was comprised of individuals in technology leadership positions in schools and libraries ranging from a large urban district (Philadelphia) to a consortium spanning large geographic areas (Panhandle Area Educational Consortium, FL). The FCC staff raised questions with the panelists about specific information regarding installations, upgrading of equipment, and the financing of WiFi networks. There was an emphasis on the roles consortia can play in making services more affordable. It seemed likely that the FCC was making the case for the various provisions they are contemplating for the upcoming modernization order.

Early Filing of Form 486s:

The FCC Form 486 for FY 2014 will be available for online filing starting Thursday, May 15th,  coinciding with the release of Wave 1. Form 486 Notification Letters will start going out soon after the first forms are filed.

Applicants can file Form 486s early, before services have started, if (a) they have received a Funding Commitment Decision Letter with approved funding; (b) their services will begin in July; and (c) they can accurately make all of the certifications required on the form. To file a Form 486 before July 1st, use the checkbox in Item 6a.

The SLD News Brief for May 9, 2014 reminds applicants that May 27th is the deadline for  submitting FY 2014 Item 21 attachments and FCC Form 471 certifications. If the Item 21 attachment is not submitted on or before May 27th, the Block 5 funding request associated with that Item 21 attachment will be considered out-of-window. This applies equally to Form 471 certifications: if the Form 471 is not certified with either a PIN or a paper certification postmarked on or before May 27, USAC will consider the form to be out-of-window.

Applicants are urged to check USAC’s posting of a list of FRNs for which the FY 2014 missing Item 21 attachments are noted, as well as a list of FY 2014 Forms 471 that have not yet been certified. The site downloads a static Excel file that lists the outstanding Item 21 attachments with separate file for the missing Form 471 certifications. It is not unusual for applicants to have forgotten to submit the Item 21 attachment or have not certified the Form 471 during the intense activity of the open window. This is a good time to verify that you have done both. USAC and the FCC have been reluctant to waive the rule when applicants have forgotten to provide the requested documents by the due date.