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E-Rate Central News for the Week
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| Preliminary P1 + 90% P2 Demand |
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| FY 2010 | $ 3,169 million | |
| FY 2009 | $ 2,852 | |
| FY 2008 | $ 3,022 |
The FY 2010 figure (which is conservative since it does not include some applications not yet data entered) is already 11% higher than FY 2009 and 5% higher than FY 2008. As a point of reference, it should be noted that Priority 2 funding in FY 2008, which included $600 million in additional roll-over funds, only reached 87%. Unless roll-over funding for FY 2010 is more than $650 million (currently our best estimate), the Priority 2 funding threshold may barely break 90%.
E-Rate Updates and Reminders
FCC E-Rate Comment Proceedings:
The FCC is currently soliciting public comments in the following three proceedings:
- New and revised CIPA rules (FCC 09-96)
- Possible changes to the Eligible Services List ("ESL") (FCC 09-105)
- Community use of school Internet facilities (FCC 10-33)
The general rule on such FCC proceedings is that comments are due 30 days after the Orders are published in the Federal Register. The status of these proceedings is as follows:
- The initial comment period on the CIPA rules closed February 25th. Reply comments on the FCC's new CIPA rules are due March 12, 2010.
- The community usage comment period was set in last week's Federal Register. Comments are due April 5th; reply comments are due April 19th.
- Interestingly, the request for ESL comments, released last December, has still not been published in the Federal Register. We have begun to wonder if the FCC has requested a delay so that comments will not be due until after the release of the National Broadband Plan on March 17th. This Plan will likely have eligible service implications.
FCC Appointments to the USAC Board:
FCC Chairman Genachowski named five members to the USAC Board to replace previous members whose terms had expired December 31, 2009. Most importantly, for E-rate applicants, the new representative for schools is Dr. Sheryl Abshire, Chief Technology Officer, Calcasieu Parish Public Schools (in Lake Charles, LA). Dr. Abshire has been an educator for more than 36 years, serving variously as a school principal, a library/media specialist, a classroom teacher, and an adjunct college professor. She has been CTO for Calcasieu schools for eleven years.
The other new Board members and their affiliations are:
- Representative for incumbent local exchange carriers (other than Bell Operating Companies) with annual operating revenues in excess of $40 million: D. Michael Anderson, Vice President of External Affairs, Iowa Telecom
- Representative for state telecommunications regulators: Hon. Anne C. Boyle, Commissioner, Nebraska Public Service Commission
- Representative for information service providers: David P. McClure, President and CEO, US Internet Industry Association
- Representative for rural health care providers that are eligible to receive discounts: Jay Sanders, M.D., President and CEO, The Global Telemedicine Group
National Educational Technology Plan:
The Office of Educational Technology ("OET") of the U.S. Department of Education has just released a draft of its National Educational Technology Plan. According to OET, the plan "...provides the context and vision for how information and communication technologies can help transform American education. The plan provides a set of concrete goals to inform state and local educational technology plans, as well as recommendations to inspire research, development, and innovation."
Two keys points concerning the E-rate program are as follows:
- The draft plan notes that an appropriate educational role for the federal government "...is promoting equity in the infrastructure for learning through continuation of the E-Rate." "The federal government should sustain support for technology use through E-Rate and other means to insure that under-served populations have access to technology for learning."
- CIPA requirements are criticized as sometimes creating "barriers to the rich learning experiences that in-school Internet access should afford students." Specifically, the draft notes:
- Filters "... designed to protect students also block access to legitimate learning content and tools such as blogs, wikis, and social networks that have the potential to support student learning and engagement."
- "CIPA has also posed challenges to the in-class use of students' own cell phones, laptop computers, and other Internet access devices to support learning activities when schools cannot afford to purchase devices for each student."
Schools and Libraries News Briefs dated March 5 - RAL Corrections
The SLD's last News Brief discusses the very important RAL process. It should be required reading for every applicant.
A RAL (or "Receipt Acknowledgment Letter") is the correspondence the SLD sends to each applicant for each Form 471 application submitted and certified on a timely basis. The RAL summarizes the information the SLD has received on each funding request and provides a limited opportunity for the applicant to make corrections.
Barring some unusual system error, the RAL data for an application filed online should exactly match the original information submitted by the applicant. An application filed on paper, which has to be data entered by the SLD, could have errors (although we remain impressed with the accuracy of the SLD's data entry).
More importantly, the RAL process permits an applicant to correct certain information incorrectly submitted in the original application. Corrections may involve discount rates and pre-discount charges. Although such changes may generate a few extra questions from PIA, these corrections may be made even if they result in higher funding requests.
As a second check, RALs are also sent to the associated service providers, albeit only with the information related to their specific funding requests. Some service providers review this information carefully, but many do not. Applicants should not rely on their service providers to find and help correct errors.
When making RAL corrections, it is important to closely follow the instructions in the RAL itself. In some cases, the corrections are to be made on the RAL itself; in other cases, the applicant must print out and make corrections on a copy of the displayed application on the SLD Web site.
The RAL indicates that corrections can be submitted by e-mail, fax, or regular mail, but provides only a hint as to how to do so. More complete information is available on the SLD Web site in the Form 471 RAL section. In our view, the easiest way is by fax (973-599-6526). If possible, SLD receipt of the fax should be documented.
Two other points should be noted:
- The due date for submitting RAL corrections is 20 days after the date of the RAL. Although limited other changes can sometimes be made during subsequent PIA reviews, the safest way to correct errors is during the RAL period.
- If no corrections are needed, simply file the RAL. Do not return a RAL to the SLD if no changes are required.