E-rate Form 470 Filing for Fiber Networks

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Jul 25, 2017

Contributor: Gretchen Bryant

The Universal Service Administrative Company (USAC) distributes broadband funding for schools and libraries on behalf of the Federal Communications Commission (FCC) for Internet access and telecommunications services. This is accomplished through the E-rate Program where eligible schools and libraries receive discounts on their telecommunication services. Discounts are factored based on the school district’s poverty level plus it’s rural or urban status. Discounts cover from 20 – 90 percent of eligible services costs.

In their 2016 unaudited Annual Report[1], USAC reported that over 68 percent of their $1,648,596 E-rate funding commitments were for Category One services. Category One services include funding for data transmission and Internet access. In many areas, low cost, higher speed Internet access can be achieved through fiber-to-school networks. In the FCC’s Second E-rate Modernization Order, and as described in the Summary of the Second E-rate Modernization Order, fiber-to-schools options have been expanded and rules have been modified to equalize the treatment of lit and dark fiber alternatives. Additionally, permitting self-provisioned fiber networks is now a funding option when it can be demonstrated that this course of action is viable and cost effective.

Funding Year 2018 officially opened July 1, 2017, for E-rate applicants to file their FCC Form 470 for the competitive bidding phase. As interest for fiber-to-school's networks increases, the FCC’s new rules also require applicants to properly compare the cost-effectiveness of the newer fiber options. USAC published a table to help applicants understand what is required in their FCC Form 470 application when a fiber network is being considered. The following table, taken from USAC’s Schools and Libraries Program March 3, 2017, newsletter, outlines which service requests are required on the FCC Form 470 and in an applicant’s Request for Proposal (RFP)and RFP documents:

Reminders for Submitting Fiber Requests on the FCC Form 470

 If     you    are seeking bids for...

You must also seek bids for...

The minimum dropdown options that should be selected on the FCC Form 470 are...

Leased Lit Fiber (with or without special construction)


"Lit Fiber Service"

Leased Dark Fiber (with or without special construction)

Leased Lit Fiber

"Dark Fiber"
"Lit Fiber Service"

Self-Provisioned Network

Services Provided Over Third-Party Networks (including, but not limited to, leased lit fiber)

"Transport Only – No ISP Service" *

* "Transport Only – No ISP Service" is a technology-neutral way of seeking support for bandwidth including, but not limited to, leased lit fiber. To select Leased Lit Fiber only would be insufficient.

Posting reminders:

  • Post an FCC Form 470 for all of the services you are seeking. Only mentioning a service in your RFP insufficient.
  • Don’t forget that if you need Internet Access services, you must post for those separately if you are considering any of the above options.
  • When posting for Self-Provisioned Networks, you must post for services provided over a third-party networks on the same FCC Form 470, unless you already posted for services provided over a third party network and received no bids in response.
  • Remember to post for any Network Equipment and/or Maintenance and Operations services if needed.
  • If you indicate you have an RFP, make sure all of the services you request on the FCC Form 470 are included in your RFP.

Providers searching the FCC Forms 470 for fiber opportunities should also review service requests posted under "Transport Only – No ISP Service." [2]

As fiber continues to grow in popularity for low cost, high speed Internet Access in the E-rate program, The FCC has responded by equalizing the treatment of fiber services allowing more cost effective broadband funding for schools and libraries. For more information on USAC’s direction on fiber networks and E-rate, please see their FAQs: Dark & Lit Fiber page.