FCC Grants E-rate Appeal Filed by Broadband Legal Strategies, LLC
Order Clarifies E-rate Applicants May Share Self-Provisioned Networks with Third-Parties
Broadband Legal Strategies, LLC, announces today that the FCC’s Wireline Competition Bureau has granted Park Hill School District’s E-rate appeal, overturning USAC’s decision to deny the school district $1.2 million in federal funding. In its decision, the Bureau found that Park Hill School District did not violate the E-rate program rules by sharing its self-provisioned network with the city of Kansas City, Missouri.
Park Hill’s Attorney, Gina Spade, of the law firm Broadband Legal Strategies, LLC, stated, “I am very pleased with the FCC’s decision to permit school and libraries to share their own fiber networks with third-parties. Park Hill’s network design saved its own taxpayers and contributors to the federal universal service fund hundreds of thousands of dollars. This common sense decision from the Commission will encourage future program participants to likewise adopt cost-saving strategies that meet their needs.”
In the order, the Bureau clarified that: 1.) E-rate participants are not required to exclusively own and operate self-provisioned networks; 2.) E-rate participants may share their self-provisioned networks with ineligible third-parties so long as the third-parties pay their fair share of the undiscounted costs; and 3.) E-rate participants bear the burden of demonstrating the cost allocation method used to determine the third party’s fair share is reasonable.
The Bureau concluded that Kansas City had paid its fair share of the undiscounted costs associated with the construction of Park Hill’s network. The Bureau also noted that the arrangement between Park Hill and the city resulted in cost savings to the Universal Service Fund and furthered the Commission’s efforts to encourage cost-effective purchasing in the E-Rate program. As a result, the Bureau granted Park Hill’s appeal and directed USAC to reinstate the school district’s E-rate funding for FY 2016 and 2017.
Broadband Legal Strategies, LLC, is a boutique telecommunications law firm providing FCC experience and knowledge to help clients comply with the E-rate and Rural Health Care program requirements. Congress established these important universal service programs nearly 20 years so that schools, districts, libraries, health care facilities, or states can reach their telecommunications and technology goals.
Broadband Legal Strategies, LLC, announces today that the FCC’s Wireline Competition Bureau has granted Park Hill School District’s E-rate appeal, overturning USAC’s decision to deny the school district $1.2 million in federal funding. In its decision, the Bureau found that Park Hill School District did not violate the E-rate program rules by sharing its self-provisioned network with the city of Kansas City, Missouri.
Park Hill’s Attorney, Gina Spade, of the law firm Broadband Legal Strategies, LLC, stated, “I am very pleased with the FCC’s decision to permit school and libraries to share their own fiber networks with third-parties. Park Hill’s network design saved its own taxpayers and contributors to the federal universal service fund hundreds of thousands of dollars. This common sense decision from the Commission will encourage future program participants to likewise adopt cost-saving strategies that meet their needs.”
In the order, the Bureau clarified that: 1.) E-rate participants are not required to exclusively own and operate self-provisioned networks; 2.) E-rate participants may share their self-provisioned networks with ineligible third-parties so long as the third-parties pay their fair share of the undiscounted costs; and 3.) E-rate participants bear the burden of demonstrating the cost allocation method used to determine the third party’s fair share is reasonable.
The Bureau concluded that Kansas City had paid its fair share of the undiscounted costs associated with the construction of Park Hill’s network. The Bureau also noted that the arrangement between Park Hill and the city resulted in cost savings to the Universal Service Fund and furthered the Commission’s efforts to encourage cost-effective purchasing in the E-Rate program. As a result, the Bureau granted Park Hill’s appeal and directed USAC to reinstate the school district’s E-rate funding for FY 2016 and 2017.
Broadband Legal Strategies, LLC, is a boutique telecommunications law firm providing FCC experience and knowledge to help clients comply with the E-rate and Rural Health Care program requirements. Congress established these important universal service programs nearly 20 years so that schools, districts, libraries, health care facilities, or states can reach their telecommunications and technology goals.
