SECA Year in Review
During Calendar Year 2020, SECA’s work has concentrated on seeking relief and educating the FCC about applicants’ needs stemming from COVID-19. SECA has been at the forefront to seek relief from the FCC on behalf of applicants while also continuing to raise important program issues in need of clarification and reform.
Initially, SECA’s web site has undergone a redesign during COVID-19 and is a repository for FCC orders and appeal decisions which are largely indexed, catalogued and searchable. (https://secaerate.net/) This content is available to the public free of charge as part of our public service mission. A list of all school State E-rate Coordinators, as well as timely updates regarding the E-rate program are available there as well. We intend to continue adding content to the web site so as to assist all stakeholders in locating information about E-rate that may not be available from other online sources.
With respect to our advocacy efforts, we have submitted numerous filings and requests for relief:
On April 23, 2020, SECA submitted a letter requesting the FCC to adopt a more generous policy of granting waivers for late filed Form 471 applications. (SECA Letter to FCC 04.23.2020) We were gratified to see that the FCC indeed has been more lenient and understanding of the need for waivers of the Form 471 filing deadline.
On August 3, 2020, we submitted a letter requesting the FCC to allow applicants to supplement their original FY 2020 applications to obtain more funding for additional on-campus connectivity necessitated by different learning models stemming from COVID-19. (SECA Additional Funding Request 08.03.2020) SECA then conducted a survey and shared the results with the FCC to quantify the impact of the request on the E-rate fund. (SECA Letter Re Addl Internet Cost 08.27.2020) On September 16, the FCC granted our request and opened a special second filing window to grant relief in FY 2020. (September 16 2020 FCC Order)
We also have submitted filings to seek relief from the burdensome requirement to cost allocate a NIF’s usage of shared Category 2 networking equipment (SECA PFR NIF Cost Allocation 1.21.2020) and the perceived limitations of what can be plugged into a switch or structured cabling drops. (SECA Ltr re Cost Allocation 07.17.2020) Further, SECA raised these issues, along with the overlap of the three Category 2 buckets of service, the need to allow schools to use their Category 2 funds for inter-school fiber connections, and the need to fully fund advanced firewall services in its comments to the FY 2021 Draft Eligible Services List. (SECA ESL Comments 08.20.2020, SECA ESL Reply Comments 09.04.2020)
Charter schools and school districts in more than a dozen states were impacted by the narrow definition of administrative authority which had created an impasse related to sharing of Category 2 budgets. To seek a resolution, SECA submitted recommendations to the FCC on how to classify charter schools for purposes of filing for E-rate, most of which were adopted in a recent Public Notice issued by the FCC. (Charter School Ex Parte 09.08.2020, FCC PN 10.14.2020)
SECA also submitted two major filings in the fourth quarter of 2019, regarding the Form 470 dropdown menu recommendations: