The overall count of Form 470 requests for proposals is down compared to last year at the same time. The pace of Category 2 (C2) postings is down 31%, a significant decline that is certainly impacted by the lack of instruction for C2 in 2020. The FCC is currently considering making permanent the rules for C2 applications. Although applicants are still allowed (and even encouraged) to release their RFPs for on-campus networks, it appears that many of them are waiting to hear from the FCC before they proceed.
 
 
The pace of Category 1 (C1) postings is also down but by a much smaller percentage. In addition to the lack of clarity about next year’s C2 rules, many applicants are waiting to learn the date the Form 471 filing window will close prior to starting their competitive bidding.

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We ask that the FCC release its final FY2020 Category Two rules. Meanwhile, all applicants can proceed with their Category 1 and Category 2 Form 470s postings.