Special Construction Regulatory Challenges
On March 11, 2019, EducationSuperhighway and the Benton Foundation met with FCC E-rate staff to discuss regulatory challenges facing applicants as they have been applying for fiber special construction projects. These two organizations also drafted a White Paper that provides further detail and a road map for the FCC to follow to curb some of the fiber regulations and USAC standards.
EducationSuperHighway and the Benton Foundation specifically would like the Commission to direct USAC to:
- Disclose the basis for its cost-effectiveness reviews, including any economic models that are used as any part of the process of review,
- Set forth in any order finding that the cost-effectiveness standard has not been met the precise and specific bases for its conclusion,
- Suspend the use of any or all questionnaires to delay or deny E-rate applications until the substance of those questionnaires has been subject to a public notice-and-comment process including the process of the Paperwork Reduction Act to the extent that it applies. USAC should also be instructed that the suspension of such questionnaires must not be allowed itself to cause delay in the review of E-rate applications.
- Immediately publish all examples of what USAC has previously considered to be a cardinal change.
The White Paper can be viewed here.