[Erate] E Rate Central News for the Week of August 22, 2005

Tue Aug 23 20:51:17 PDT 2005

E‑Rate Central News for the Week of August 22, 2005

*        Wave 9 Funding for FY 2005

*        Proposed Eligible Services List for FY 2006

*        National SECA Survey on E-Rate Effectiveness

*        SLD E-Rate Training Sessions

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 and service providers.  To learn more about our services, please contact us by phone (516-832-2880) or by e-mail <mailto:services at e-ratecentral.com>  (services at e-ratecentral.com).  Additional E-rate information is located on the E‑Rate Central Web site <http://www.e-ratecentral.com/>  (http://www.e‑ratecentral.com <http://www.e%1eratecentral.com/> ).

*        Wave 9 Funding for FY 2005

Wave 9 for FY 2005 is scheduled for release on Wednesday, August 24, 2005.  Funding in this wave is estimated to be about $29 million for over 500 applicants.  Total funding for FY 2005 is now $546 million.

Internal Connections for FY 2005 are still not being funded; Priority 2 funding could begin as early as Wave 10 next week.

A very small wave (#30) for FY 2004 is scheduled for release on Tuesday, August 23, 2005.  It will provide an additional $175 thousand in funding for only a few applicants.  Total funding for FY 2004 is now $2,283 million, which is actually slightly down from last week because of funding cancellations.

*        Proposed Eligible Services List for FY 2006

The proposed Eligible Services List (“ESL”) for FY 2006 was posted for comment by the FCC last Tuesday (see http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-05-158A1.doc <http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-05-158A1.doc> ).  To highlight the changes, many of which are simply clarifications, the SLD posted a one-page summary on their Web site at http://www.sl.universalservice.org/data/pdf/Summary%20%20of%20Proposed%20Changes.pdf <http://www.sl.universalservice.org/data/pdf/Summary%20%20of%20Proposed%20Changes.pdf> .  The following ten changes are of special interest:

1.      A special note has been added to page 1 of the ESL warning applicants that some bundled services offered by carriers, such as combinations of local telephone and Internet services, must be applied for separately for E-rate purposes.  This means that the telecom and Internet services must be requested in separate categories in an applicant’s Form 470 and as separate FRNs in an applicant’s Form 471.  One reason for this separation is to assure that all Internet services are subject to CIPA requirements (which do not otherwise apply to telecommunications services).

Although not crystal clear in the new ESL, this separation requirement does not apparently affect broadband access (e.g., T-1 or cable modem circuits) provided by an ISP as a part of an integrated Internet service.

2.      The entry on Internet WANs was expanded to clarify that eligibility “…is limited to basic conduit access to the Internet. Funding in this category will not be provided for transport of point-to-point connectivity of data, video, or voice applications that are to be provided only by telecommunications carriers.”  We believe that this clarification was made, in part, to stress that only an allocated Internet portion of full-service WANs provided by non-telecommunications companies are eligible for E-rate discounts.  To be fully eligible, a WAN must be provided by an eligible telecommunications provider, as indicated by a “Y” in the ETP column of the SLD’s SPIN Search database.

3.      The entry for Wireless Internet Access was expanded to indicate that services “…designed for portable devices easily transportable to ineligible locations will not be funded unless an auditable system is in place to allocate between eligible and ineligible uses.”  Although not explicitly stated, this provision seems to support recent reductions in funding requests for e-mail and Web access services from Blackberry-like devices.  It is not immediately clear what “auditable systems,” if any, could be employed to make portions of such services eligible.

4.      Several Telecommunications entries involving video transmission services were expanded slightly to make it clear that components “…such as scheduling, content creation, and storage are not eligible.”  The current ESL just mentions “content” as ineligible.

5.      The entry for VPN components was changed from fully ineligible to being more generally eligible “…if they provide basic and reasonable security protections to prevent unauthorized access to the information, software, and systems of an applicant’s eligible components.”  This change apparently reflects the view that many VPN components provide firewall like functions.

6.      Conversely, the entry for Network Switches was modified from fully eligible to include language indicating that some switches may include ineligible components (e.g., support for network management).

7.      A new entry was created for Terminal Servers indicating both eligible (e.g., terminal access to Internet services) and ineligible (e.g., terminal access to application software) functions.

8.      Basic Maintenance has been broken off into a separate section, if only to recognize that Internal Connections maintenance is now a separate service category.

9.      A new entry was created in the Miscellaneous section for Redundant Components and Duplicative Services, both of which are ineligible.

10.  Another new entry was created in the Miscellaneous section to clarify that late payment fees are not eligible.  This should serve as a useful reminder to applicants who are now summarizing bills in preparation for filing BEAR reimbursement forms for last year’s services.

The new ESL will not become effective until released as a formal FCC Order later this fall.  Parties interested in commenting on the proposed list must do so quickly.  Comments are due this week by August 25th; reply comments are due September 1st.  For comment purposes, please note the cautionary note in the Public Notice that the “…proceeding is limited to determining what services are eligible under the Commission’s current rules; it is not intended to be a vehicle for changing any eligibility rules.”  Changes in basic eligibility rules can be addressed as a part of the FCC’s broad Notice of Public Rulemaking (“NPRM”) on the E-rate and other Universal Service programs, with comments due October 18th (see http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-05-124A1.doc <http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-05-124A1.doc> ).

*        National SECA Survey on E-Rate Effectiveness

The Administration, Congress, and the FCC are taking a hard look at the E-rate program, actively debating whether the program has been a success or failure.  Although the vast majority of applicants have reported that the program is highly beneficial, and there is considerable data on actual funding, there is little information available on the program’s impact and operation.

To address these critical issues, the State E-Rate Coordinators’ Alliance (“SECA”) has developed an online E-rate survey which SECA is asking all school applicants (but not regional consortia) to complete over the next two weeks.  E-Rate Central believes that this survey is important to the future of E‑rate, and we urge — indeed, beg — every school or school district to complete it.

The survey consists of 28 questions.  It should not take more than 10-15 minutes to complete.  Responses will be aggregated on both a national and statewide basis.  Individual responses will be kept confidential.  (Contact information is being requested only to help screen out duplications and provide statewide totals.)

The survey can be accessed online at http://www.zoomerang.com/recipient/survey-intro.zgi?p=WEB224KB8TD3EW <http://www.zoomerang.com/recipient/survey-intro.zgi?p=WEB224KB8TD3EW> .

Note that this survey applies only to schools, not libraries.  A library E-rate survey, sponsored by ALA and the Gates Foundation last spring, addresses many of the same issues.  The results of this survey are available at http://www.ala.org/ala/washoff/oitp/GatesFinalJun05.pdf <http://www.ala.org/ala/washoff/oitp/GatesFinalJun05.pdf> .

*        SLD E-Rate Training Sessions

The SLD announced three one-day E-rate training sessions to be held this fall — one in Washington, DC (9/30), one in Los Angeles, CA (10/11), and one in Newark, NJ (10/21).  The sessions, entitled "ABCs of the Schools and Libraries Program," are open to applicants, service providers, state coordinators, and consultants.  

Space for the training sessions is limited and is available on a first come, first served basis.  The Washington session is already fully subscribed, and there is a waiting list.  The Newark session is currently open for registration, and the Los Angeles session should be open for registration this week.  To attend, you must register online at https://ww2.eventrebels.com/er/Registration/LandingPageEntry.jsp?ActivityID=684 <https://ww2.eventrebels.com/er/Registration/LandingPageEntry.jsp?ActivityID=684> .  

In addition to the SLD training, many states offer E-rate workshops each fall.  One place to start looking for these training opportunities is on your state’s E-rate Web site or contacting your state E-rate Coordinator.  Lists of E-rate Web links and E-rate Coordinators are available on a state-by-state basis on the E-rate Central Web site at http://www.e-ratecentral.com/us/default.asp <http://www.e-ratecentral.com/us/default.asp> . 

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Disclaimer: This newsletter may contain unofficial information on prospective E‑rate developments and/or may reflect E‑Rate Central’s 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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