Upcoming Dates:
| September 16 |
Due date for reply comments on the FCC’s proposed Eligible Services List (“ESL”) for FY 2025 (DA 24-743). |
| September 17 |
Opening date for filing Form 484 Part 1 to apply for participation in the FCC’s Cybersecurity Pilot Program (see article above). The Form 484 Part 1 window closes on November 1st. |
| September 17 |
USAC Webinar: Pilot Program Form 484 Part 1 System Walkthrough (registration). |
| September 19 |
With the exception of a couple of amendments subsequently published in the Federal Register, the FCC’s hotspot order (FCC 24-76) becomes effective on this date. |
| September 19 |
As the result of the hotspot order becoming effective, the FY 2025 Form 470 also becomes available (see E-rate News Brief of August 28th discussed below). |
| September 23 |
Form 486 deadline for FY 2023 Wave 55. 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 for FY 2023 are:
Wave 56 10/17/2024
Wave 57 10/28/2024 |
| September 30 |
Last day to receive service or to submit a Service Delivery Deadline request for FY 2023 non-recurring services. |
| October 15 |
USAC webinar: Cybersecurity Pilot Program Overview for Service Providers (registration). |
| October 28 |
Due date for nominations for eight positions on the USAC Board of Directors (see DA 24-867). |
| October 28 |
E-rate invoice deadline for FY 2023 recurring services. |
| October 29 |
Form 486 deadline for FY 2024 Waves 1-10. 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 for FY 2024 are:
Wave 11 10/31/2024
Wave 12 11/08/2024 |
USF Quarterly Contribution Factor Hits a New High:
The FCC announced (DA 24-924) that the Proposed Fourth Quarter 2024 Universal Service Contribution Factor will be 35.8% — continuing its upward climb and breaking 35% for the first time. This is not good news at a time when the FCC is initiating a new USF-funded cybersecurity pilot program and expanding E-rate funding to cover residential hotspots for students and library patrons.
The underlying problem continues to be, not so much that USF expenses (i.e., revenue requirements) are rising, but that interstate telecommunications revenues (i.e., the contribution base) have fallen sharply over the last decade and a half. The only real long-term solution would be to expand the contribution base with internet service and/or content provider revenues.
The increase in the USF contribution factor comes at a particularly critical time for dealing with USF issues. As discussed in our newsletter of July 29th, the 5th Circuit Court of Appeals recently issued a decision finding that the USF funding mechanism was unconstitutional. In part because the 6th and 11th Circuit Courts of Appeal had previously ruled to the contrary, the 5th Circuit’s decision has currently been stayed pending an expected FCC petition for a writ of certiorari to the Supreme Court. Hopefully, this controversy will encourage Congressional action to restructure the Universal Service Fund along the line suggested above.