This post discusses how to file E-rate reply comments with the FCC, otherwise known as the Federal Communications Commission. As mentioned in the post on June 4, 2016, the FCC have released the draft eligible services list (ESL) for E-rate funding year 2017. Remember that E-rate funding year 2017 is the year from July 1st 2017 to June 30th 2018. The eligible services list is the list of services that the FCC will subsidize with Universal Service Funds. In other words, for you to get subsidy from the FCC for school broadband services, the service must be listed in the Eligible Services List.
The list will be finalized by the FCC in the fall (a specific finalization date has not been set).
The FCC has released the draft ESL to receive comments from all interested parties. Thus, if you would like to suggest a service that you believe should be eligible, or you have comments on the draft text, you can submit comments to the FCC. There are two deadlines for submitting comments to the FCC. The first deadline is July 5, 2016. The second “Reply Comment” deadline is July 20, 2016. The “Reply Comment” deadline is if you have read the comments submitted by other parties, and you wish to agree and support those comments, you can file “Reply Comments” – where you state your support for other comments filed.
When you are providing comments to the FCC, it is much more valuable and effective to include your own experience and background as to why you want the FCC to implement your proposed changes. Talk about the impact to your school, how your school would benefit from the change. What I do not recommend is reusing a standard form letter that somebody else has written – and just signing your name on the bottom. This is not as effective, in my opinion, in influencing the FCC.
If you believe you have input to provide to the FCC, the first thing to do is look at what comments other people have provided. Go to the FCC website https://www.fcc.gov/ecfs/ If you forget this link just go into the google search engine, and type in the following term “search comments FCC”. You should see the below page:
In the field “Specify Proceeding (Optional)” type in the docket number for the E-rate proceeding, which is 13-184.
If you want to search for specific text, you can enter the text in the first field. If you scroll down the page, you will see you can specify a date range, for when the FCC received the comments. Since the draft ESL for funding year 2017 was released on June 3, 2016, you can specify the date range from June 3, 2016 to your current date.
In the search results page, you will see comments filed by other parties. Wait until after July 5th, to see other parties’ comments that filed before the July 5 2016 deadline.
You can file E-rate Reply Comments either via a Standard Filing or Express Filing. A Standard Filing requires you to upload your Reply Comments i.e. your Reply Comments are a separate document. An Express Filing allows you to enter text directly into the FCC webpage.
If you opt for a Standard Filing, you should create a document describing your support for other filers comments. When you wish to support a filer’s comments, specify the name of the filer, and section number of their comments – so you can be specific regarding what you support. As I mentioned in Part 1, you should include your own experience as to why you support other filers comments. The FCC is particularly interested in hearing about your experiences resulting from the E-rate modernization as relates to the Eligible Services List. The front page of your filing should reference the Docket number – which is 13-184. Look at how other filers have filed their comments and do the same for your front page of your Reply Comments.
Please note the deadline for filing Reply Comments is 20 July 2016.
The following sections describe how to (i) search the FCC database for submitted comments (ii) submit a standard filing and (ii) submit an express filing.
Searching the FCC database for Submitted Comments
- Go to the URL https://www.fcc.gov/ecfs/
- In the second field/text box called “Specify Proceeding (Optional)” type in 13-184 then press the ‘Enter’ key on your keyboard
- Your screen should look as below
- Scroll to the bottom of the webpage and click “Search”
- The most recent comments submitted will appear. Your webpage should look similar to the below:
- To view other parties comments, click on the file.
- If you wish, on the search page (step 2), you can submit additional filter criteria such as date range, or text.
- Go the URL https://www.fcc.gov/ecfs/filings
- The webpage should look as below:
- In “Proceeding(s)” type in 13-184 then press Enter. Please note, you have to press Enter and not just move the cursor to another line. This is the same with the other fields – you have to press Enter.
- In “Name(s) of Filer(s)” type in the name of the filer. The filer can be any entity, for example, a school district, or a person. If you are representing a school district I recommend the Filer be the school district. If you are representing yourself and not the school district, then include your own name as the Filer.
- If you do not have a law firm assisting you, leave the entry “Law Firm(s)” blank.
- In the “Attorney/Author Name(s)” field, type in your name.
- Put the primary contact’s email address in “Primary Contact Email”
- In “Type of Filing” select from the drop down menu “Reply to Comments”
- For the Fields “File Number”, “Report Number” and “Bureau ID Number” leave these blank
- In the “Address of” field, scroll down to Filer.
- In the “Address”, “Address 2”, “City”, “State” and “ZIP” fields, enter the address of the Filer.
- If on your page you do not see the orange highlight, go back to the field, enter the information again and this time press “Enter”. If you do not press Enter, the orange highlight will not appear.
- After you have entered the Filer address you are ready to upload your comments. Your comments typically should be in PDF or WORD format. However, the FCC does allow other formats to be uploaded. The full list of acceptable formats is shown in the “Upload Documents” field.
- In the “Upload Documents” field, click on the text starting with “Click or drop files here: PDF, text, …”. Navigate to your comments, select the file, then press “open”.
- In the description text box, provide a brief description of your file. Or this can be left blank. (When people search for comments they can hover over the file without opening it. When people hover over the file, the text you entered in Description will appear. If you left this text box blank, the name of the file will appear.)
- Click on “Email Confirmation” to receive an email confirmation of your filing, then click “Continue to review screen”
- On the next page, check your entries then click “Submit” at the bottom of the page. If you need to make any corrections click the back button on your browser.
- The FCC typically takes about a day to make the document publicly available.
- To check if your document is publicly available, please see the section “Searching for FCC Comments”.
- Go to the URL https://www.fcc.gov/ecfs/filings/express
- For the fields “Proceeding(s)”, “Name(s) of Filer(s)”, “Primary Contact Email”, “Address”, and the remaining address fields, please see the section “Standard Filing” in this post for instructions.
- Check the box “Email Confirmation” if you want to receive an email confirmation of your filing.
- Enter your comments in “Brief Comments” then click “Continue to review screen”
- If you are satisfied with your entries, click Submit. If not, click the browser back arrow to edit.
- Note that the express filing does not allow file uploads. The standard filing does allow file uploads, as demonstrated in the instructions “Standard Filing” in this document.
Good luck filing with the FCC. Email me if you have any questions.