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E-rate News for the Week
December 10, 2001

The following is a summary of the E-rate News for the Week of December 10, 2001, prepared by E-Rate Central. Official SLD news appears in the “What’s New!” section of the SLD’s Web site . Additional and archived information appears elsewhere on the E-Rate Central Web site.

PY4 Wave 10 Released

Wave 10 of Funding Commitment Decision Letters (“FCDLs”) was mailed on Friday, December 14. Total funding in this wave was $34 million. Applicants receiving FCDLs in this wave, and planning to take time off for the holidays, should review them quickly in case an appeal needs be filed within the 30-day window. Holding to its normal two-week cycle, the SLD plans to release Wave 11 on December 28.

Cumulative funding for PY4 now stands at $1.728 billion, with an estimated 15-20% of available funding yet to be awarded. Funding for internal connections is still being awarded only to applicants at the 90% discount level. Applicants at the 85-89% level are currently being funded for telecommunications and Internet access, but are being advised that their internal connection requests are as yet unfunded.

Reminder: Form 470 Deadline for PY5 Applications

The last possible day to file a PY5 Form 470 online for next year’s application is next Friday, December 20. Form 470s posted on this date will have an Allowable Contract Date, 28 days after posting, of January 17, the last day of the Form 471 application window.

At this point in the application cycle, it is strongly recommended that no attempt be made to file a Form 470 by mail. Even if the SLD receives a Form 470 in the mail next week, there is no assurance that it will be data entered by Friday to start the 28-day posting period.

SLD Update on Bundled Services

Our previous Weekly News discussed an initial SLD pronouncement on bidding procedures and cost allocations involving both eligible and ineligible services, commenting that the language seemed to suggest that a single RFP for both services might be viewed as a non-competitive process and that additional clarification was expected.

A clarification was posted on the SLD’s home page Wednesday. It discusses two methods — "cost allocation" in general cases and "ancillary use" in special situations — for dealing with a mix of eligible and ineligible services or components. Specifically, with regard to the bidding process for mixed services, the SLD warns that the “cost allocation” guidelines must be employed. Any PY5 applicant that bid for such a service without adhering to these guidelines need not re-bid the service, but should request separate pricing for eligible and ineligible components from the bidders.

Form 486 Notification Letter Appeals

The SLD has begun sending Notification Letters to applicants who have filed Form 486s for PY4 services. No applicant notification is being provided for PY3 or earlier filings. It is recommended that Form 486 Notification Letters be carefully reviewed as soon as they are received so that any potential errors can be addressed in a timely fashion. A formal appeal, if necessary, must be received by the SLD (or FCC) within 30 days of the Letter’s date. There are several specific problem areas to be reviewed.

  1. Make sure that all FRNs listed on the original Form 486 are also listed in the Notification Letter, and that the Form 471 Application Numbers and Funding Request Numbers (“FRNs) are correct.If there are errors or omissions, we suggest calling the SLD Help Line (888-203-8100) to see if corrections can be easily made. If not, it may be necessary to file an appeal.

  2. Check the Service Start Date. If the SLD made a change, the date should be marked with an asterisk and an explanation should be included. A date change could affect future BEAR filings and/or funding amounts

  3. If the SLD believes that the Form 486 was filed after the applicable CIPA deadline, it may have changed the Service Start Date to the Form 486 filing date, with a resulting loss of funding. In this case, the Notification Letter will include an Adjusted Funding Commitment field. If this occurs, an applicant’s only likely recourse is an appeal.

E-rate Training Material Available

Slides from E-Rate Central’s half-day training sessions held in New York last month, and the more extensive slides from the SLD’s two-day national Train-the-Trainer workshop held in September, are now available for review on the E-Rate Central Web site. .

Disclaimer: This newsletter may contain unofficial information on prospective E-rate developments and/or may reflect our own interpretations of E-rate practices and regulations. Such information is provided for planning and guidance purposes only. It is not meant, in any way, to supplant official announcements and instructions provided by either the SLD or the FCC.
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