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April 15, 2024


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 2024 – The Application Window is Closed:

The Form 471 filing window for FY 2024 closed on March 27th.  The preliminary demand total is $3.2 billion, up from $2.9 billion last year.  As of last Friday, the FCC had received over 300 waiver requests for late-filed Form 471 applications for FY 2024.

E-Rate for FY 2023:

USAC issued Wave 51 for FY 2023 on Thursday, April 11th, for $6.62 million for two large city applicants. Total funding is $2.61 billion.  At this point, USAC has funded 98.0% of the originally submitted applications representing 94.3% of the dollars requested.

Upcoming Dates:

April 18 USAC webinar on Program Integrity Assurance (“PIA”) and Selective Reviews (registration).
April 19 Form 486 deadline for FY 2023 Wave 35.  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 36              04/26/2024
Wave 37              05/03/2024
Wave 38              05/10/2024
Wave 39              05/17/2024
Wave 40              05/24/2024
May 28 Extended invoice deadline for FY 2022 non-recurring service FRNs.
June 30 Last day to receive FY 2023 recurring services and all ECF Window 3 services.
June 30 Last day to light fiber (or request an extension) for special construction projects from FY 2023.
August 29     Invoice deadline for ECF Window 3 applications.

ACP Phase-Out Continues:

With no affirmative relief from Congress to provide extended funding for the Affordable Connectivity Program (“ACP”), the FCC reluctantly continues its plan to shut down the discounted internet program for low-income households.  Last week, the FCC issued a Public Notice (DA 24‑342) reiterating that this April will be the last month of full reimbursements and formally setting the maximum reimbursement amounts for the month of May.

ACP Phase-Out

The FCC is encouraging service providers to take efforts to keep as many ACP households as possible connected to broadband service after the end of the program by offering to move them to low-cost internet service plans that the providers already offer or that they newly adopt as an offering to low-income consumers.

School Bus Wi-Fi and TikTok:

Sen. Ted Cruz (R-TX) and seven Senate colleagues filed an Amici Curiae brief in the U.S. Court of Appeals for the Fifth Circuit last week in support of private action initiated on behalf of Maurine and Matthew Molak seeking review of the FCC’s move to make school bus Wi-Fi equipment and services eligible for E-rate support.  The Senators’ brief, echoing earlier press releases, argues that:

The FCC has provided no evidence that unsupervised children and teenagers with smartphones on school buses will opt to do their classwork rather than scroll through TikTok and Instagram, nor has the agency taken into account the countervailing dangers of enabling unsupervised social media use and its numerous documented threats to children—including cyber-bullying, development of mental health problems, exposure to pornography, and targeting by predators.

Editorial Comment: The Senators’ position does not acknowledge the importance of compliance with the Childrens’ Internet Protection Act (“CIPA”) requirements governing student internet usage within schools — and now equally applicable on Wi-Fi-equipped school buses.  But this is something that schools need to be thinking about carefully.

The implementation of a “technology protection mechanism,” commonly referred to as a “filter,” will be particularly important on school buses if only because one aspect of CIPA, not often discussed, requires the “monitoring” of online activities by minors.  The assumption within a school environment is that such monitoring will be provided by teachers and staff.  On a bus, however, the only adult supervision is typically the driver who is obviously in a poor position to “monitor” student internet usage.

Filtering, if properly implemented, can provide a required degree of monitoring by tracking actual computer Wi-Fi usage.  Rather than simply filtering out inappropriate content, bus Wi-Fi systems can be configured to track and record which sites users have attempted to access.*  The results of such a control and monitoring system, as reported by the Farmington (NM) Municipal School District, an early adopter of school bus Wi-Fi, is shown below.  In Farmington’s case, their system only permits internet access through the district’s own system, itself filtered, or to other carefully vetted educational sites (see pie chart on the left).  The system also tracks, but blocks, attempted access to all other sites (see pie chart on the right).

Farmington Municipal School District Internet monitoring on school buses

To Senator Cruz’s point, it appears that extensive student access to services such as TikTok is a real possibility with school bus Wi-Fi.  What he needs to acknowledge, however, is that schools have CIPA-conforming tools to assure that school bus internet access is utilized for true educational purposes.

* A similar approach might be used to monitor hotspot usage once implemented by the FCC and USAC.