Upcoming Dates:
| July 10 |
USAC will hold another rescheduled version of its cybersecurity webinar (registration). Those interested in a more detailed discussion may want to review a recording of the Cybersecurity Pilot webinar hosted by E-Rate Central on July 26 (see slides). |
| July 12 |
Form 486 deadline for FY 2023 Wave 47. More generally, the Form 486 deadline is 120 days from the FCDL date or the service start date (typically July 1st), whichever is later. Upcoming Form 486 deadlines are:
Wave 48 07/19/2024
Wave 49 07/26/2024
The first Form 486 deadline for FY 2024, for applicants funded on or before July 1st, will be October 29th. |
| July 18 |
FCC Open Meeting to include consideration of the proposed Report and Order and Further Notice of Proposed Rulemaking to make off-premises use of Wi‑Fi hotspots and wireless internet service eligible for E-rate funding (see draft Order currently on circulation). |
| August 1 |
Current USAC estimate of Form 470 availability for Funding Year 2025. |
| August 1 |
USAC webinar on FCC Form 470/Competitive Bidding (registration). |
| August 29 |
Invoice deadline for ECF Window 3 applications.* Please note that invoice deadline extension requests are unlikely to be approved. |
FCC Streamlined Decisions:
The FCC issued another set of “streamlined,” precedent-based, appeals and waivers last week. As with past streamlined decisions, applicants facing similar problems as those addressed in these decisions may garner useful information by carefully reading the additional FCC explanations found in the footnotes. The original appeal and/or waiver requests can be found online in the FCC’s Search for Filings under Docket 02-6 (E-rate) or Docket 21-93 (ECF).
In June’s streamlined decisions (DA 24-608), the FCC:
- E-Rate Dismissed:
- Two Petitions for Reconsideration for failure to identify any material error, omission, or reason warranting reconsideration.
- E-Rate Granted:
- One Request for Waiver allowing a service delivery extension.
- One Request for Review on cost-effectiveness “finding that where there is only one bid responsive to the FCC Form 470, the responsive bid necessarily offered the lowest bid.”
- One Petition for Reconsideration for a late-filed Form 471 due to delays beyond the applicant’s control.
- One Request for Waiver for the inadvertent cancellation of a Form 471.
- Two Requests for Waiver for Form 471 applications filed more than 30 days late due to serious illnesses.
- Twelve Requests for Waiver for Form 471s filed within 14 days of the close of the window.
- One Request for Waiver of a late-filed Form 486.
- Three Requests for Waiver involving ministerial and/or clerical errors.
- One Request for Waiver based on the reconsideration of a Bureau decision.
- Two Requests for Waiver of invoice deadlines where USAC post-commitment decisions were not issued until after the deadlines had passed.
- Ten Requests for Waiver of the special construction service delivery deadline.
- E-Rate Denied:
- Eighteen Requests for Waiver of late-filed Form 471s filed more than 14 days late and failing to present special circumstances justifying a waiver.
- Four Requests for Waiver of invoice deadline extensions.
- One Request for Waiver for ministerial and/or clerical errors.
- One Request for Waiver for a service implementation delay.
- Five Requests for Waiver for untimely filed appeals or waivers.
- One Request for Waiver of the Form 470 and Form 471 deadlines.
Correction: Form 470 Delay for FY 2025
In last week's newsletter, we had noted — correctly — USAC’s announcement that the FY 2025 version of the Form 470, normally available on July 1st, would be delayed this year. The delay reflects the highly likely need to support competitive bidding for off-premises use of hotspots and wireless internet service, whose eligibility is expected to be approved by the FCC at its July 18th Open Meeting (see our newsletter of July 1st). We had suggested last week that applicants needing to file early Form 470s for other FY 2025 services could use the older FY 2024 Form 470 version as long as they clearly indicate in that form’s narrative section that they are seeking services for FY 2025. Unfortunately, this advice is no longer valid since the FY 2024 version of the Form 470 has been removed from the USAC website. Unless USAC comes up with a fix, the only option now for applicants wishing to file early FY 2025 Form 470s is to wait for the new version to become available — hopefully later this month (or early in August) after a final FCC decision on hot spots.