On December 6, 2021, several E-rate stakeholders sent a joint letter to the FCC regarding the draft Notice of Proposed Rulemaking that proposes to implement a central bidding portal through which service providers would be required to submit their bids to the E-rate Program Administrator. The Commission’s formal vote to adopt the E-rate bidding NPRM is scheduled for December 14, 2021.
In their letter to the Commission, the coalition recommended modifications to the draft NPRM, including:
- The proceeding name should be re-titled “Improving the E-rate Competitive Bidding Framework” so as to minimize any misconception or confusion regarding the existence of competitive bidding requirements.
- We request 90 days from Federal Register publication for the submission of initial comments and 45 additional days for submission of replies
- Instead, the Commission should specifically seek comment (without offering any tentative conclusions) on the following five areas to address the concerns raised by the FCC’s Office of Inspector General and the General Accounting Office
- The proposal to require all applicants to upload all bidding documents as part of the Form 471 application should be further clarified.
The coalition noted that the revisions will ensure that a robust and thorough record of the current mode of operation of the competitive bidding practices will be compiled and that this approach will better enable the Commission to make informed decisions on how best to improve the E-rate competitive bidding framework.
The coalition letter to the FCC can be viewed here