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Category Two Clarifications Sought

Two recent Petition for Reconsideration filings with the Federal Communications Commission request additional information or rule changes related to the Commission’s recent Category Two clarification Order.
On November 13, 2020, the State E-rate Coordinators’ Alliance (SECA) filed a Petition for Consideration asking the FCC to consider its January request that the cost-allocation requirement for Category Two services used by non-instructional facilities (NIFs) be eliminated.  Stating that the FCC’s C2 clarification Order “simply restated the requirement that was included in the December 2019 Category Two Report and Order,” SECA asserts that their prior Petition for Reconsideration has not been adequately addressed by the FCC and “requests that the FCC fully consider and grant the relief requested.”  SECA’s prior Petition for Reconsideration asked the FCC to eliminate the requirement that applicants cost-allocate the portion of shared Category Two equipment and services consumed by NIFs.
On November 16, 2020, E-rate Central acting as the New York state E-rate Coordinator submitted a Petition for Reconsideration asking the FCC “to clarify that its Category 2 rules on part-time students apply broadly to independent schools or districts that are attended by students from multiple districts on a part-time or full-time basis,” expressing concern that “USAC may be intending to interpret” the Category Two clarification order “too narrowly as to unduly limit the FCC’s true intent.”
SECA’s Petition for Reconsideration may be found here.
E-rate Central’s Petition for Reconsideration may be found here.
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