E-Rate Central News for the Week
November 23, 2009
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 (516-832-2887) or through our Contact Us Web form. Additional E-rate information is located on the E-Rate Central Web site.
FY 2008 and FY 2009 Funding Status
Wave 29 is scheduled for release on November 24th for $134 million. This brings cumulative FY 2009 funding to $1.44 billion. Priority 2 funding is still being provided for discounts of only 85% or more, and is now being denied at 54% and below.
Wave 73 for FY 2008 will be released on November 25th for an undisclosed amount. Priority 2 funding at 87% is still pending.
Responses to the FCC's Request for E-Rate Comments
Last Friday marked the initial deadline for responding to the FCC's request for comments on E-rate, education, and the National Broadband Plan (see DA 09-2376).
At least 30 parties submitted comments. For the most part, the comments supported maintaining the E-rate program in its current form, albeit stressing the need for additional funding and the possibility of using E-rate funded broadband facilities by a wider community of users. As perhaps best stated by Palm Beach County schools, "E-Rate can contribute to the success of the broadband effort, but should not be dismantled to leverage or fund additional priorities."
Some of the larger organizations submitting comments on E-rate issues included:
The deadline for submitting reply comments on these issues is December 11th.
In a related development involving the forthcoming National Broadband Plan, the FCC issued a news release last week listing challenges cited by a task force gathering data and developing draft proposals. After nearly 40 workshops, 10,000 comments, and 15 public notices, the task force reported that it had identified many key "gaps in the pathway to universal broadband." Most importantly, the task force noted that, despite over $7 billion in Universal Service Funds being spent annually:
- The majority of USF funding supports affordable phone service, not broadband.
- The four USF programs – high-cost support for rural phone service, support for advanced services in schools and libraries, support for phone service to low-income families, and rural health care support – are not coordinated to maximize deployment opportunities to fill broadband gaps.
- The high-cost funding mechanism rewards inefficiency and funds is [sic] not determined by broadband needs.
- An unsustainable funding mechanism and increased demands for support have doubled the amount paid by consumers since 2000.
- Accountability is limited for use of high-cost funds for broadband support.
Other "gaps" identified relate to broadband adoption, consumer information, spectrum, deployment, and television set-top box innovation (see FCC broadband gap release). Taken together, these findings suggest that the FCC's National Broadband Plan may recommend major changes to the Universal Service Fund. While many of these changes may focus on the high-cost fund, E-rate may also be affected - another reason that E-rate comments discussed above are important.
E-Rate Updates and Reminders
Fall E-Rate Training:
Copies of the SLD's 2009 Training Slides are available on the SLD's Web site.
Service Provider access to online Item 21 attachments:
The SLD announced that service providers now have access to certain Item 21 attachments, but: (a) only for those attachments filed online; and (b) only for those submitted by their customers (i.e., they cannot view online Item 21 attachments for FRNs linked to other service providers). Information on this new capability is available on the SLD Web site under the section Service Provider Access to Online Item 21s.
The SLD News Brief for November 20, 2009, discusses the relationship between an applicant's technology plan and its Form 470(s). The SLD states the following:
Your technology plan, if properly done, forms the basis for the acquisition and use of the services featured on your Form 470. By describing your current and future needs, your goals and strategies for using technology, and a budget that includes both your non-discount share and the resources you need to effectively use discounted services, you can prepare reasonable funding requests and evaluate and monitor your progress toward reaching your technology goals.
The services you request on your Form 470 should follow from your goals and strategies and your current and future needs as described in your technology plan. This helps to ensure that the products and services for which E-rate provides discounts will be put to good and effective use.
The remainder of the News Brief asks and answers the following questions (which we recommend that applicants review carefully):
- How do I avoid an overly broad Form 470?
- How long and detailed should my technology plan and Form 470 be?
- What effect should my needs assessment [one of the five required technology plan components] have on my Form 470?
- How specific should I be about the scope of my project?
- What effects could minor or major changes to my technology plan have on my Form 470?
News Archive
