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Friday, September 05, 2014

When will we see the 470?

Normally, USAC allows us to start posting Forms 470 for the following year sometime around July 1st.  This year, we're waiting for the new form.  OK, how long will we be waiting?  Call CSB, and they'll say it will be available "soon."  Well, according to Office of Management and Budget (OMB):
"The following process is used to obtain OMB approval for an information collection.

  1. The agency develops an information collection that it wishes to implement.
  2. The agency publishes a Federal Register notice about the proposed information collection and provides the public with 60 days to provide comment on the proposed collection.
  3. The agency considers the public’s comments and makes changes as appropriate to address concerns raised by the public.
  4. The agency submits the ICR to OMB for review and publishes a second Federal Register notice announcing the start of OMB’s review. The second notice provides the public with an additional 30 days to provide comments.
  5. After reviewing the ICR and considering public comments, OIRA concludes its review by approving the collection or taking one of the other actions noted above."

The latest rumor I'm hearing is that the draft form will be available by the end of the month.  So let's make a little timeline:
Sept. 26: FCC releases the draft for public comment.
Oct. 2: The notification hits the Federal Register.  The 60-day comment period starts.
Dec. 1: The 60-day comment period closes.
Dec. 8: After spending a week ignoring the public comments (just kidding), the FCC sends the forms to the OMB.
Dec. 17: Notice is published in the Federal Register that the forms have been sent to OMB.  The 30-day comment period starts.
Jan. 16: The 30-day comment period closes.  OMB begins reviewing the forms and public comments.
Feb 11: OMB approves the form. (I can't find any guidelines for how long the OMB takes, but this seems to be about how long it took to approve the 470 changes in 2013.)

That is not an outlandish or pessimistic timeline.  So if USAC is johnny-on-the-spot and releases the Form 470 the next business day, it will be available on Feb. 12.

So an applicant who isn't busy that day can file on Feb. 12, giving them an Allowable Contract Date of March 12.  The latest rumors I've heard is that the window will close mid-March, so those applicants have maybe a week to select a vendor, negotiate and sign a contract, and file their Form 471.

Not to worry: a recent USAC News Brief said that we can use the old form, as long as we note in Item 13 that the form is for FY 2015-2015.  But what's this notice in bold at the bottom of the News Brief?  "[I]f your services will be non-contracted services provided under tariff or on a month-to-month basis, you MUST wait until the FY2015 option is available online before you file your FCC Form 470."

True, most services are going to be under contract (with telecom rates dropping so fast, service providers are desperate to lock in today's rates), but what district doesn't have a BANA circuit or POTS line for alarms or environmental controls or fax lines or whatever?  So what now, I file a 470 now for contracted service, and file a separate 470 just for some stupid POTS line?

This program just keeps getting simpler and simpler.

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