August 22, 2017

Simplified Drop-down Options for Eligible Services on FY2018 FCC Form 470

On Saturday, August 26, 2017, a simplified set of drop-down options will be available to applicants completing FCC Form 470 to request bids for eligible services in the E-rate Productivity Center (EPC). The simplified drop-down options will apply to FCC Forms 470 filed for FY2018 on or after that date. If you have already filed an FCC Form 470 for FY2018, or plan to do so between now and August 26, 2017, you do not need to refile FCC Form 470. FCC Forms 470 filed using both the current and simplified drop-down options in EPC will be accepted for FY2018, subject to program rules.

GUIDELINES AND TIPS ON THE SIMPLIFIED FCC FORM 470 DROP-DOWN OPTIONS

Why has USAC streamlined the drop-down menu options in EPC for applicants filing FCC Form 470?

Applicants complete FCC Forms 470 by submitting information in EPC. One feature of the FCC Form 470 in EPC is a drop-down menu from which applicants can select the eligible services for which they would like to seek bids. After the close of competitive bidding for FY2016 and FY2017, USAC received helpful feedback from program participants indicating confusion about the EPC drop-down menu options that should be used to seek bids for certain eligible services (particularly fiber services), and which options should be used to comply with the specific competitive bidding requirements applicable to Leased Dark Fiber and Self-Provisioned Networks.

The simplified drop-down menu options to be implemented on August 26 address these issues, and are accompanied by additional helper text to assist applicants with identifying the options that should be used to effectively request bids for particular eligible services. In addition, these simplified options and accompanying filing guidance will help streamline search efforts for service providers by making it easier for them to identify bid requests for fiber and other eligible services.

Has anything else changed about how applicants complete FCC Form 470 through EPC?

No. The amount and type of information that applicants are required to submit and certify when completing FCC Form 470 through EPC will not change. The only changes being made on August 26 are to the presentation of the eligible service drop-down options in the EPC tool, and the provision of additional helper text in EPC.

How do the simplified drop-down options in EPC assist applicants with complying with the competitive bidding rules applicable to Leased Dark Fiber and Self-Provisioned Networks?

The competitive bidding rules specific to Leased Dark Fiber and Self-Provisioned Networks require applicants to request competitive bids for certain additional services when considering either solution. The simplified drop-down options in EPC make it easier for applicants to comply with these requirements by including the additional services for which applicants are required to seek bids in the same drop-down option when requesting bids for Leased Dark Fiber or a Self-Provisioned Network. Previously, applicants had to use multiple, separate drop-down options to request bids for these additional services.

Specifically:

• Leased Dark Fiber: Pursuant to program rules, applicants considering a Leased Dark Fiber solution for their connectivity needs must also request bids for a Leased Lit Fiber solution. The simplified drop-down option in EPC makes it easier for applicants to comply with this requirement by providing a combined "Leased Dark Fiber and Leased Lit Fiber" selection that must be used if an applicant wishes to consider proposals for Leased Dark Fiber. Required use of this drop-down option will help ensure that applicants complete FCC Forms 470 to request bids for both types of services. Of course, applicants can request bids for additional services by using additional drop-down options.
• Self-Provisioned Networks: Program rules require applicants that are considering a Self-Provisioned Network solution for their connectivity needs to also request bids for services provided over third-party networks. To facilitate compliance with this requirement, the simplified drop-down option in EPC now features a combined "Self-Provisioned Network and Services Provided Over Third-Party Networks" selection that must be used if an applicant wishes to consider proposals for a Self-Provisioned Network. Using this drop-down option will help ensure that applicants complete the FCC Form 470 to request for bids for a Self-Provisioned Network, as well as for services provided over third party networks on a technology-neutral basis (e.g., Leased Lit Fiber, Leased Dark Fiber, microwave).

Of course, simply listing all desired and required services for which an applicant is seeking bids in an FCC Form 470 does not fulfill an applicant’s obligation to conduct an open and fair competitive bidding process and select the most cost-effective service offering. Applicants are responsible for ensuring that they take all steps necessary to comply with program rules. The simplified drop-down options will, however, help applicants avoid the potential misstep of not effectively seeking bids for all required services when considering a Leased Dark Fiber or Self-Provisioned Network solution.

What if we are only interested in a Leased Lit Fiber solution?

Applicants who are only interested in considering Leased Lit Fiber proposals must use the "Leased Lit Fiber" drop-down option in the simplified EPC menu implemented on August 26.

Of course, as stated above, applicants will also be able to consider Leased Lit Fiber proposals if they are requested by using the "Leased Dark Fiber and Leased Lit Fiber" or "Self-Provisioned Network and Services Provided Over Third-Party Networks" drop-down options. As discussed in more detail below, however, applicants must not use any other drop-down option (e.g., "Internet Access and Transport Bundled") to request bids for Leased Lit Fiber after the simplified drop-down options are made available on August 26.

When the simplified drop-down options are implemented in EPC, may "Transport Only – No ISP Service" be used to seek bids for Leased Dark Fiber and "Internet Access and Transport Bundled" be used to seek bids for Leased Lit Fiber?

No. After the simplified drop-down options are implemented, applicants who wish to consider proposals for Leased Dark Fiber or Leased Lit Fiber must request them using the fiber-specific drop-down options provided. "Transport Only – No ISP Service" and "Internet Access and Transport Bundled" will remain options in the EPC drop-down tool, but may only be used to request bids for non-fiber services. These instructions are stated in the helper text that will accompany the simplified drop-down options, and will help reduce confusion about the options applicants should use when seeking bids for fiber services. It will also help service providers identify and respond to the full scope of FCC Forms 470 requesting bids for fiber services.

Applicants should:

• Use the "Transport Only – No ISP Service Included" drop-down option when they are interested in considering proposals for transport services provided over third party networks that do not include commercial Internet Access service, other than Leased Dark Fiber (e.g., copper, microwave). Reminder: Applicants interested in considering proposals for a Leased Dark Fiber solution must request bids for Leased Dark Fiber by using the "Leased Dark Fiber and Leased Lit Fiber" drop-down option in EPC.
• Use the "Internet Access and Transport Bundled" drop-down option when they are seeking bids for managed services provided over third party networks that include commercial Internet Access service, other than Leased Lit Fiber (e.g., DSL). Reminder: Applicants interested in considering proposals for a Leased Lit Fiber solution must request bids using the “Leased Lit Fiber” drop-down unless they have already requested bids using the "Leased Dark Fiber and Leased Lit Fiber" or "Self-Provisioned Network and Services Provided Over Third-Party Networks" drop-down options in EPC.

Has anything changed about how applicants should seek bids for just internet access?

No. Applicants will continue to use the "Internet Access: ISP Service Only" function when seeking bids for commercial Internet Access service only, or in conjunction with a separate transport solution. Remember: "Internet Access: ISP Service Only" does not contain any type of transport, including Leased Lit Fiber.

What drop-down options will be available for Voice and/or Cellular Service?

• Use the "Cellular Data Plan/Air Card Service" drop-down option when you are only seeking bids for a commercial wireless data plan only. Please Note: If you are seeking cellular voice service in addition to cellular data service, also utilize the "Cellular Voice" function.
• Use the "Cellular Voice" drop-down when you are only seeking bids for commercial wireless voice service with no data or texting services. Please Note: If you are seeking cellular data service in addition to cellular voice, you should also utilize the "Cellular Data Plan/Air Card Service" function.
• Use the "Voice Service" drop-down option to request Analog, Digital, or Interconnected VoIP voice service.

What if the service I want is not listed in the simplified set of drop-down options?

Use the "Other" drop-down and provide additional detail about this service by uploading an RFP document. This option should also be selected if you are seeking support for: (a) Network Equipment, such as modulating electronics and other equipment necessary to make a Category One service functional; or (2) maintenance and operation costs for Leased Dark Fiber or a Self-Provisioned Network.

What if I've already filed an FY2018 FCC Form 470 for eligible services?

If you have already filed an FCC Form 470 using the current drop-down options in EPC, you do not need to refile an FCC Form 470. Your existing FCC Form 470 filing for FY2018 will remain an effective request for bids for the eligible services that you identified, subject to program rules.

If you would like to refile your FCC Form 470 to use the simplified drop-down options, you may do so. Please be advised, however, that filing a new FCC Form 470 will restart the competitive bidding process for those services, and you will be required to comply with all program rules applicable to a new competitive bidding process, including the requirement to wait 28 days before entering an agreement with a service provider.

Will USAC publish instructions and/or guides with more information about using the new drop-down options in EPC when completing an FCC Form 470?

Yes, USAC will publish a user guide to help applicants familiarize themselves with using the new drop-down options. This information will be posted to the website by August 26, 2017.

Who can I contact if I still have questions about how to use the new drop-down options in EPC after reviewing the user guide?

If you have questions concerning the new drop-down options that are not addressed here or in the reference material available via our website and EPC, or about the E-rate program generally, please contact the Client Service Bureau at (888) 203-8100.