The extension was a cautionary move by the SLD to avoid potential appeal problems resulting from an error that appeared in an early version of the SLD's annual Letter to the Field. The Letter, which contains important filing deadlines and program rule advisories, initially indicated that the last possible day to file a Form 470 for FY 2005 would be January 21. The date should have been January 20. The SLD quickly realized the error, updated its Web site, and re-faxed Letters to applicants who had received the incorrect version.

Upon reflection, the SLD realized that there may have been some applicants who relied upon the original Letter. Any applicant filing a Form 470 on January 21st would have an Allowable Contract Date of February 18th, one day after the original Form 471 deadline. By extending the deadline one day, the SLD avoids possible grievances related to the Form 470 deadline error.

The corrected copy of the FY 2005 Letter to the Field - which we encourage all applicants to read - is available on the SLD Web site (see Letter to the Field).

We suspect that many applicants have viewed this Item 25 certification as a mere formality. To the SLD and FCC, however, supporting resources are critical. Documentation of an applicant's financial ability to provide these resources is, and has been, one of the two key targets of the detailed Selective Review process. To further emphasize the importance of this requirement, the Item 25 certification on this year's Form 471 has been expanded and, for the first time, requires actual budget numbers. We have noticed some applicant confusion on the Item 25 data fields, so we're providing the following guidance:

(1) The amounts in the Item 25 data fields "a," "b," and "c" summarize the funding requests in the Form 471. Field "a" is the total of the prediscount amounts (Item 23i) for all Block 5s; similarly field "b" is the total of the discounted amounts (Item 23k) requested. Field "c" is the difference, i.e., the amount the applicant would have to pay if all E-rate funding in that Form 471 were to be approved and utilized.

(2) Field "d" is the so-called Item 25 resources amount. It is meant to represent the applicant's budget for all supporting, but ineligible, E-rate technology services. The comparable number requested in a Selective Review would be the sum of more detailed budget entries for:

• Hardware – computer workstations, printers, scanners, video equipment, telephone handsets, and other ineligible technology equipment used to support educational or library services.
• Professional staff development – technology and related curriculum training including course fees, instructional material, peer monitoring, etc.
• Software – ineligible software including productivity tools, curriculum software, library content, etc.
• Retrofitting – expenses necessary to make effective use of E-rate equipment such as electrical system upgrades, wiring closet construction, computer lab renovation, etc.
• Maintenance – operating costs of maintaining ineligible hardware and software, including salaries of technology staff personnel.

Note: Field "d" should also include E-rate eligible services for which E-rate discounts are not being requested - e.g. an applicant with a low E-rate discount rate that hasn't bothered to apply for discounts on eligible network maintenance should include the costs of the service in this field.

(3) Field "e" is the sum of the applicant's undiscounted E-rate expenses (field "c") and its other ineligible technology expenses (field "d"). For an applicant filing just one Form 471, this figure should represent the applicant's total budget for technology and telecommunications for next year. An applicant should be prepared to document this amount either in its current technology plan budget or from the appropriate technology and telecommunications accounting codes in its operating budget. If next year's budget has not yet been finalized, the current year's budget may serve as a proxy.

(4) If an applicant files more than one Form 471 - e.g., one for Priority 1 services and another for Priority 2 services - it is important to note that fields "a," "b," and "c" are specific to the individual applications, while the Item 25 "d" field would be the same for each application.

Note that total FY 2003 funding exceeds the program's nominal cap of $2.25 billion. This is a result of the FCC's decision in 2003 to begin rolling over unused funds from prior years into future years. For FY 2003, the first year of the new policy, the roll-over amount was set at $420 million - a first year bonanza that was more than twice the roll-overs for FY 2004 or FY 2005 - bringing the FY 2003 cap to $2.67 billion.