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Year 7 (2004) Internal Connections Funding Threshold Finalized at 81%
Message Posted May 3, 2005

The SLD announced on Friday that the funding threshold for Internal Connections, which was set at 81% in early January, would not be reduced any further for Funding Year 7.  All outstanding Priority 2 requests at 80% and below, including those previously listed “As Yet Unfunded,” will now be denied.

The decision to not fund lower than 81% Year 7 Internal Connections came as a shock to everyone in the E-rate community.  Rather than announcing an early percentage limit at which Internal Connections would definitely not be funded, the SLD continued to review Priority 2 requests at all levels.  The 81% level, set in the first funding wave after the enactment of the program’
s temporary exemption from the Anti-deficiency Act (“ADA”), was widely seen
as just the first step in lowering the Year 7 threshold.

E-rate Central just uncovered the deeper issue in an unpublicized letter, dated March 11th, in which USAC notified the FCC that it had erred in recommending a reduction in the funding threshold to 81%.  At this level, USAC projected that funding commitments would exceed the Year 7 cap of $2.4 billion (including $150 million of roll-over funds) by $159 million. Apparently, the proper threshold should have been only 85%.

The USAC letter proposed three alternative approaches to dealing with this problem: (a) permit USAC to over-commit funds for Year 7 (which the FCC has the authority to do based on projections that not all committed funds will be actually used); (b) roll-over additional unused funds from prior years into Year 7; or (c) immediately cut back Priority 2 funding to 85%, and cancel commitments already made at 81-84% (a decision which would have had potentially disastrous consequences for some applicants).

Although we have not seen a formal decision by the FCC, we assume that Friday’s 81% announcement confirms that option (c) was not selected. Internal Connections funding down to the 81% level should be safe for Year 7.

A copy of the March 11th letter is available on the FCC Web site at
http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_documen
t=6517495234.

Julie Tritt Schell

jtschell@comcast.net
(717) 730.7133 (voice)
(717) 730.9060 (fax)

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