FCC Requests Comments on SPIN Changes
Message Posted June 9, 2000
As you know, on March 16, the FCC released an Order (commonly referred to as the Copan Decision) that relaxed the rules for making SPIN changes. The SLD then submitted comments to the FCC asking for a reconsideration and clarification of the Copan decision because they felt that the Order was vague in certain sections, and would be very difficult for them to administer.
The FCC is now looking to the school and library community for comments on the Copan decision. Comments may be submitted via e-mail, using the template below, and must be received by June 16. Because the FCC rarely hears comments directly from the applicant community, and because this issue is so vital to the interests of schools and libraries, you may want to consider writing a few paragraphs with your opinions on the issues they have outlined.
Issue Recap
In the Copan decision, the Commission basically through out the old SPIN change rules and ruled that SPIN changes now would be permissible whenever an applicant seeking support certifies that:
1) the SPIN change is allowed under state and local procurement rules and under the terms of the contract between the applicant and the original service provider; and
2) the applicant has notified the original service provider of its intent to change service providers.
(Full Copan Order text available at: www.fcc.gov/Bureaus/Common_Carrier/Orders/2000/fcc00100.txt)
Then, on April 14, the SLD filed a petition for reconsideration and/or clarification of the revised standard for permissible service provider identification number (SPIN) changes set forth by the Commission in its Copan Order. (Full SLD reconsideration text available at: https://gullfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6011256308) Specifically, SLD seeks further guidance from the Commission on the following issues:
1) whether the Copan guidelines are applicable to both pre-funding commitment and post-funding commitment SPIN changes; (meaning: can you submit a SPIN change request after you submit your 471, but before you receive your Funding Commitment Letter, or do you have to wait until you receive your Letter in order to submit a SPIN change)
2) whether the Copan guidelines are applicable to tariff and month-to-month service arrangements; (meaning: the Copan decision refers to contracts and says nothing about tariffed or month-to-month services. If you would like the opportunity to change vendors for tariffed services, then you should comment on this section.)
3) whether the principles set forth in the Copan decision should have retroactive effect; (meaning: should you be allowed to change service providers for Year 2, including the vendor changes you made in the middle of year 2 but were not permissible under the old SPIN change rules, OR should the new rules only be in effect from this point forward.)
4) whether a new Form 470 must be posted by a new service provider; and (meaning: should the new service provider that you choose have had to participate in the original or completely new competitive bidding process, or none at all.)
5) how the Copan decision relates to changes in service content (meaning: should you be allowed to change service providers AND make changes to the original service or product requested and still keep E-rate discounts.)
Now, the FCC has given all interested parties until June 16 to submit comments on the Copan decision and the SLD's comments. Comments must be in the template format I've included below and should be e-mailed to: ecfs@fcc.gov. If you would like to have the FCC automatically e-mail you a copy of the template and example, send an e-mail to ecfs@fcc.gov, and include the following words in the body of the message, "get form <your e-mail address>."
Comments should refer to “CC Docket No. 96-45” and “File Number SLD-26231.”
You must keep everything in brackets, then list your information AFTER the brackets... Here is the template
<PROCEEDING> 96-45 -- keep this number the same
<DATE> list the date that you submit comments here
<NAME> list your name here
<ADDRESS1> list your mailing address here
<ADDRESS2>
<CITY> list your city here
<STATE> list your state here
<ZIP> list your zip here
<LAW-FIRM>
<ATTORNEY>
<FILE-NUMBER> 00-03 -- keep this number the same
<DOCUMENT-TYPE> CO -- keep the CO the same
<PHONE-NUMBER> list your phone number
<DESCRIPTION> Comment on USAC Petition -- keep these words the same
<CONTACT-EMAIL> insert your e-mail address
<TEXT>
Before the
Federal Communications Commission
Washington DC 20554
In the Matter of )
Federal Communications )
Commission Request for Comment ) DA 00-1194
Copan Public Schools ) File No. SLD-26231
Copan, Oklahoma )
Federal-State Joint Board on ) CC Docket No. 96-45
Universal Service )
Changes to the Board of Directors of ) CC Docket No. 97-21
The National Exchange Carrier )
Association, Inc. )
use school district's name here COMMENTS ON ADMINISTRATOR’S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION
Then simply reply to what they seek comments on. Include as many examples as you can and why or why not you want them to act in a certain way.
Julie Tritt Schell
Executive Policy Specialist
Pennsylvania Department of Education
333 Market Street, 10th Floor
Harrisburg, PA 17126
(717) 705-4486
(717) 787-7222 - fax
jtritt@state.pa.us
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