E-rate 2.0: Rural vs. Urban - Determining Your Status - Second Update
The following is a guest article for the Funds For Learning® web site from Justin A. Volker with Clinton CUSD #15 in Illinois. This is the second update to the original article, which has been updated with the changing rules as they have been developed by the FCC.
On December 19, 2014 the FCC issued a Second Report and Order and Order on Reconsideration (Second Order). This Second Order changed the mechanism by which a school or library applicant will determine eligibility for the “rural discount bonus.” This marks the third such change since the start of the FCC’s recent E-rate modernization initiative. Applicants are encouraged to read the original article and the first update to get the full picture of this shifting landscape.
Here’s the thrice-amended language of § 54.505 (b)(3)(i), as it now stands:
The Administrator shall designate a school or library as “urban” if the school or library is located in an urbanized area or urban cluster area with a population equal to or greater than 25,000, as determined by the most recent rural-urban classification by the Bureau of the Census. The Administrator shall designate all other schools and libraries as “rural.”
Thus, applicants are returned to a two-tiered classification examination. The process is similar to that explained in the original article, but now slightly more complex. In order to determine the proper classification, an applicant should refer to the "national, state-sorted list of all 2010 urbanized areas and urban clusters for the U.S., Puerto Rico, and Island Areas first sorted by state FIPS code, then sorted by UACE code" located here: https://www.census.gov/programs-surveys/geography/guidance/geo-areas/urban-rural/2010-urban-rural.html
You can download this data in excel (XLS) or text (TXT) format under the "Lists of 2010 Census Urban Areas" section. The first area of focus should be the twelfth column (L). This is the legal/statistical area description (LSAD) code for the area listed in the second column (B). LSAD code 75 indicates an urbanized area, while code 76 indicates an urban cluster. Applicants with LSADC 76 must then focus on the fifth column (F), which displays the population of the listed area. If the listed population in this column is equal-to or greater-than 25,000, the applicant is considered urban. If the value is less-than 25,000, the applicant is considered rural. An applicant that does not appear on the list as either a UA or a UC is, by definition, classified as rural. For reference, you can see a table of all the LSAD codes here: https://www.census.gov/library/reference/code-lists/legal-status-codes.html
Here’s a table condensing all this information into a quick-reference format:
The FCC has directed USAC to host an Urban/Rural Lookup Tool on its website to identify which areas are rural, and to keep it updated each year. However, it’s important for applicants to know how to check this status for themselves because the FCC’s Second Order also reminds applicants “that they have an obligation to ensure that they are seeking the correct discount rate.”
Justin A. Volker manages the E-rate program for his rural, central Illinois school district. Aside from being a self-proclaimed tech geek, he has a law degree and finds the ongoing evolutionary fusion of law and technology fascinating. He enjoys analyzing laws and regulations, travel, video gaming, stock investing, and connecting with folks who share similar passions. You can find his online home at http://www.JustinAVolker.com