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Spring 2010 E-rate Update
Message Posted May 2, 2010

Happy Spring, E-raters! I wanted to take this opportunity to provide you with an E-rate update on several pending issues:

E-rate NPRM - The FCC has announced that at their May 20 Open Meeting, they will vote to release a Notice of Proposed Rule Making (NPRM) specifically related to the E-rate recommendations contained in the National Broadband Plan that was released in Mid March. The National Broadband Plan, available at http://download.broadband.gov/plan/national-broadband-plan.pdf, set forth 12 E-rate recommendations, but few specifics on how to implement each recommendation. This NPRM is the document which will seek comments from the E-rate community on very specific ideas, some of which are expected to be controversial. After the NPRM is released, it must be published in the Federal Register (which could take a month or two), and then stakeholders will have 30 days to submit comments, and then 30 days to submit reply comments. I will keep you posted on this significant NPRM as it is released and analyzed.

2010 FCDLs - USAC is expected to begin issuing FY 2010 Funding Commitment Decision Letters (FCDLs) very soon. For those applicants lucky enough to be funded in Wave 1, the next step will be to file the Form 486. Although it will probably be several months until Priority 2 applications are funded, USAC has reported $900 million in unused funds from previous years that is available for rollover into FY 2010. If the FCC approves the rollover (which they have typically have done), it likely means that FY 2010 80% funding requests -- or lower -- could again be funded.

Status of FY 2009 Applications:
-- Priority 1 (telecom and internet): About 96% of PA applications have been funded in waves 1-50. The remaining 207 P1 FRNs that have not yet been funded are worth $9.6 million and I understand from USAC that these funding requests are being actively reviewed.

-- Priority 2 (internal connections and basic maintenance): Priority 2 funding is still being approved at 80% and above, and denied at 69% and below, although it is expected that the threshold may go lower than 80%.

-- In all, PA applicants have been committed nearly $89 million in FY 2009.

Beginners Training - Because many new E-rate contacts have joined their schools and libraries since the fall Beginners Training was held, a 2-hour E-rate Training Webinar is being scheduled in May. Watch for details to be released this week.

CIPA Amendment - In October 2008, Congress passed the "Protecting Children in the 21st Century Act," which contained a provision requiring schools' Internet Safety Policies to include "... educating minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response." Essentially this means that schools will be required to teach online safety to students as a prerequisite to receiving E-rate funding. Although the law is 19 months old, the FCC has not yet released the official Order that will implement the new requirements and set deadlines for compliance. I believe that the Order, when released, will have the new provisions begin July 2011. In the meantime, we do recommend that if you are currently writing or rewriting your Internet Safety Policy, be sure to include this new provision. In addition, your school should be thinking about how you will actually implement the new law when it does become effective, if you aren't providing such online behavior education already. (Libraries are exempt from the new provision.)

Technology Plans - Don't forget that technology plans covering July 1, 2010 - June 30, 2011 are required to be approved by July 1, 2010. If you're a public school entity and are unsure about the status of your technology plan, contact Joan Adams at 717-732-8403. A list of public school entities that do not yet have their plans submitted will be issued in the next few weeks.

Audits - Although the FCC has promised that the harsh FCC OIG attestation audits that applicants endured over the last three years will not be repeated, IPIA audits are slated to resume in the next few months. Specifically, we anticipate more audits than before (720/year as opposed to 250), but the audits will be conducted nearly entirely from remote locations and are slated to last only a few days, unlike the 3-6 week on-site audits that we previously experienced. I'll keep you posted as more details are released.

E-rate Timeline - Having trouble keeping track of E-rate deadlines from three funding years at the same time? Attached is a timeline that I usually hand out at the beginners trainings, but I thought it might be useful for all PA applicants.

As always, if you have any questions, please contact me at jtschell@comcast.net.

-Julie

717-730-7133 - o
717-730-9060 - f
jtschell@comcast.net
www.e-ratepa.org
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