What’s New in E-rate for Summer 2010
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From the Ed Tech Office - Summaries:
FCC Requesting Input for Proposed E-rate Changes:
The Federal Communications Commission (FCC) has asked for input from applicants, vendors, and the public regarding proposed modifications to the E-rate program through a process known as NPRM (Notice of Proposed Rule Making). Please read below for more details of the proposed changes to the program. Please be aware that no changes have been decided yet!
What does this mean to you and your application timing? Some of these changes may take place in the fall and next year. USAC will be clarifying any proposed changes at the Washington DC training in late September, so it is anticipated that any changes that would affect Funding Year 2011 will be solidified by that time. CDE/K12HSN will ensure that any changes to the program will be outlined in our scheduled trainings to make sure California applicants have this information. It is more important than ever to plan on attending the free CDE/K12HSN E-rate trainings. Please see scheduling information below.
What should you do? Right now all you can do is follow the same practices as you did in previous years, using current forms. The FCC/USAC will honor that until they OFFICIALLY announce program changes.
We encourage you to read the more specific details outlined below.
Reminder: Sign up for Fall E-rate Training NOW!
The California E-rate Training provided by CDE/K12HSN will be even more important this year than in the past in light of proposed changes to the E-rate program. The Beginner trainings will start in September and Intermediate/Advanced trainings start in October. The Intermediate/Advanced sessions will address any NEW FCC/USAC training information and rule changes. So please sign up now!
All training sessions are available for attendance in person, by videoconference, or by live steaming to your computer. Details on the trainings and registration are available online at:
http://www.k12hsn.org/
Details of Changes to the E-rate Program Proposed by the FCC
As mentioned above, the FCC has entered into a series of Proposed Rule Making proceedings to potentially change some of the rules and eligibility guidelines of the E-Rate program in order to streamline some of the processes and position the program to help achieve some of the mandates resulting from the National Broadband Plan (NBP): http://www.broadband.gov/
It is very important to understand that the NPRM is the first step in a process that has several steps and should not be viewed as being a “done deal.” These are PROPOSED changes, not yet new rules.
In general, the areas that the FCC was requesting comment on were:
- Streamlining technology planning, application and competitive bidding processes
- Potential changes to the discount matrix (both Priority One and Priority Two)
o Calculation guidelines
o Urban/Rural designation
o Different matrices for P1 and P2
- Providing greater flexibility to select Broadband services
o Proposed rule change to once again provides discounts on leased fiber, even if unlit, from providers that may not be eligible telecommunications providers
o Proposed change to the eligibility of off campus wireless internet access use
- Re-prioritizing funding to target Broadband services
o Propose to no longer provide discounts on ‘basic voice services’
- Eligible Services List (ESL) changes
o Propose to no longer provide discounts on Web Hosting services
o Propose to no longer provide discounts on Basic Maintenance services
- Revamping the Priority Two funding mechanism
o Propose to make P2 funding available to more applicants throughout the Country
o Propose to abolish the Two-in-Five rule
- Indexing the current $2.25 billion cap on E-rate disbursements to inflation to maintain the purchasing power of the current program and enable continued support
The full FCC Notice of Proposed Rulemaking Documents are available at the links below:
http://hraunfoss.fcc.gov/
http://hraunfoss.fcc.gov/
Initial comments to the FCC’s Notice were due July 9, 2010 and reply comments were due July 26, 2010. The California Department of Education, along with many other constituencies, responded with comments to the proposed changes. The CDE’s comments can be found at the following links:
Initial Comments: http://fjallfoss.fcc.gov/ecfs/
Reply Comments: http://fjallfoss.fcc.gov/ecfs/
Of the many comments submitted by national applicant advocacy groups, telecommunications carriers, and individuals (including both applicant and service provider consulting firms), most had common themes:
- It is time to change some of the rules that are outdated
- It is time to simplify and streamline some of the processes
- It is time to re-think Priority Two funding availability and distribution
- It is time to consider increasing the $2.25B annual cap (There has been some private analysis that priority 1 requests will outstrip all available funding in 2 years)
While there was some consistency in the comments to the NPRM, the comment period also resulted in some mixed feelings on some subjects which is why the FCC opens these proceedings up to public comment.
Next Steps:
Now that the comment period has closed, the FCC will review and consider the comments submitted and ultimately issue an Order (or Orders) that will outline whatever new rules result from the proceedings as well as when those new rules will be applicable. Based on many recommendations in the submitted comments and discussions that California’s State E-Rate Coordinator has had with other State Coordinators and the FCC’s Wireline Competition Bureau staffs, it is unlikely that sweeping change will be effective for E-Rate Funding Year 2011. That being said, no one really knows until the Order(s) are released so, we could all be completely wrong about this.
Conversely, it is likely (but not absolute) the Eligible Service List changes (including the eligibility change regarding leased fiber and web hosting) WILL be effective for FY 2011 and beyond.
What to do?
So, how should you plan for FY2011 given that none of these proposed changes have been codified? The CDE’s recommendation at this time is:
DON’T CHANGE ANYTHING.
Proceed as though nothing has changed and continue planning for FY2011 as though this is a typical year. More information will be made available in the coming weeks and months and we will be diligent about getting any new information out to everyone as soon as it is available.
Additionally, the CDE and the K12HSN have again partnered to provide regionalized E-Rate training throughout the state beginning in the Fall. If you were on the fence about whether you need to attend the training, we sincerely hope the fact that much of what you thought you knew about E-rate is about to change will prompt you to register for and attend at least one of the sessions being offered this year. It is a PRIME opportunity for you to ask your questions and meet colleagues who work within the E-Rate program in your area.
More information including dates, times and registration instructions can be found at http://www.k12hsn.org/
Please note: The Fall 2010 training materials are currently being updated. Once you register for a session (or sessions), you will receive an email notification when the 2010 training materials are available.
If you have any further questions about this communication or any E-Rate question in general, please contact:
John Vardanega, This e-mail address is being protected from spambots. You need JavaScript enabled to view it Russ Selken, This e-mail address is being protected from spambots. You need JavaScript enabled to view it
Last Updated (Wednesday, 03 August 2011 09:45)