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 Federal  Communications  Commission  DA  02-  344 
 Before  the  Federal  Communications  Commission 
 Washington,  DC  20554 


 In  the  Matter  of  )  ) 
 Request  for  Waiver  by  )  ) 
 Newtown  Public  Schools  )  NEC.  471.01-  20-  00.5100049  Newtown,  Connecticut  )  NEC.  471.01-  20-  00.5100050 
 )  NEC.  471.01-  20-  00.5100051  ) 
 Federal-  State  Joint  Board  on  )  CC  Docket  No.  96-  45  Universal  Service  ) 
 )  Changes  to  the  Board  of  Directors  of  the  )  CC  Docket  No.  97-  21 
 National  Exchange  Carrier  Association,  Inc.  ) 


 ORDER 
 Adopted:  February  13,  2002  Released:  February  15,  2002 
 By  the  Accounting  Policy  Division,  Common  Carrier  Bureau: 
 1.  The  Accounting  Policy  Division  has  under  consideration  a  Waiver  Request  filed  by  Newtown  Public  Schools  (Newtown),  Newtown,  Connecticut.  1  Newtown  seeks  a  waiver  of  the 
 Commission’s  rules  governing  discounts  for  services  under  the  schools  and  libraries  universal  service  support  mechanism  for  Funding  Year  3  (July  1,  2000-  June  30,  2001).  2  For  the  reasons 
 set  forth  below,  we  deny  Newtown’s  Waiver  Request. 
 2.  Under  the  schools  and  libraries  universal  service  support  mechanism,  eligible  schools,  libraries,  and  consortia  that  include  eligible  schools  and  libraries,  may  apply  for  discounts  for 


 eligible  telecommunications  services,  Internet  access,  and  internal  connections.  3  In  order  to  receive  discounts  on  eligible  services,  the  Commission’s  rules  require  that  the  applicant  submit 
 to  the  Schools  and  Libraries  Division  of  the  Universal  Service  Administrative  Company  (Administrator)  a  completed  FCC  Form  470,  in  which  the  applicant  sets  forth  its  technological 
 needs  and  the  services  for  which  it  seeks  discounts.  3  The  Administrator  must  post  the  FCC  Form 
 1  Letter  from  John  R.  Reed,  Newtown  Public  Schools,  to  Federal  Communications  Commission,  filed  March  30, 
 2001  (Waiver  Request). 
 2  See  Waiver  Request.  Section  54.  719(  c)  of  the  Commission’s  rules  provides  that  any  person  aggrieved  by  an 
 action  taken  by  a  division  of  the  Administrator  may  seek  review  from  the  Commission.  See  47  C.  F.  R.  §  54.  719(  c). 
 3  47  C.  F.  R.  §§  54.  502,  54.  503. 


 4  47  C.  F.  R.  §  54.504(  b)(  1),  (b)(  3). 
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 470  on  its  website,  and  the  applicant  is  required  to  wait  28  days  before  making  a  commitment  with  a  selected  service  provider.  5  Once  the  applicant  has  complied  with  the  Commission’s 
 competitive  bidding  requirements  and  entered  into  an  agreement  for  eligible  services,  it  must  file  an  FCC  Form  471  application  to  notify  the  Administrator  of  the  services  that  have  been  ordered, 
 the  carrier  with  whom  the  applicant  has  entered  into  an  agreement,  and  an  estimate  of  funds  needed  to  cover  the  discounts  to  be  given  for  eligible  services.  6  The  Commission’s  rules  allow 
 the  Administrator  to  implement  an  internal  filing  period  (“  filing  window”)  for  the  FCC  Form  471  applications  that  treats  all  schools  and  libraries  filing  within  that  period  as  if  their  applications 
 were  simultaneously  received.  7  Applications  that  are  received  outside  this  filing  window  are  subject  to  separate  funding  priorities  under  the  Commission’s  rules.  8  It  is  to  all  applicants’ 
 advantage,  therefore,  to  ensure  that  the  Administrator  receives  their  applications  prior  to  the  close  of  the  filing  window.  In  Funding  Year  3,  tens  of  thousands  of  applicants  successfully  filed 
 their  FCC  Forms  471  within  the  filing  window. 
 3.  Newtown  filed  its  Funding  Year  3  FCC  Forms  471  on  January  20,  2000,  one  day  after  the  filing  window  closed  on  January  19,  2000.  9  Newtown  states  that  it  left  the  forms  in  a 


 Federal  Express  mailbox  on  January  18,  2000,  for  overnight  delivery,  but  that  due  to  inclement  weather,  it  appears  that  Federal  Express  was  not  able  to  pick  up  the  application  for  delivery  that 
 day.  10 
 4.  We  conclude  that  Newtown  has  not  demonstrated  a  sufficient  basis  for  waiving  the  Commission’s  rules.  Waiver  is  appropriate  if  special  circumstances  warrant  a  deviation  from  the 


 general  rule,  and  such  deviation  would  better  serve  the  public  interest  than  strict  adherence  to  the  general  rule.  11  In  requesting  funds  from  the  schools  and  libraries  universal  service  support 
 mechanism,  the  applicant  bears  the  burden  of  getting  its  forms  and  other  information  to  SLD  for  processing  within  the  established  deadline  if  the  applicant  wishes  to  be  considered  with  other  in-window 
 applicants. 
 5.  The  particular  facts  of  this  case  do  not  rise  to  the  level  of  special  circumstances  required  for  a  deviation  from  the  general  rule.  The  Commission  has  consistently  denied  requests 


 for  waivers  of  filing  windows  based  on  inclement  weather,  stating  that  such  events  as  severe  snow  storms  or  fog,  while  unexpected,  are  “reasonably  foreseeable,”  and  advised  that  applicants 
 that  wait  until  the  end  of  the  filing  period  risk  such  delivery  failures.  12  In  a  recent  order,  the 


 5  47  C.  F.  R.  §  54.504(  b)(  3),  (4);  §  54.  511. 
 6  47  C.  F.  R.  §  54.504(  c). 
 7  47  C.  F.  R.  §  54.507(  c). 
 8  47  C.  F.  R.  §  54.507(  g). 
 9  FCC  Forms  471,  Newtown  Public  Schools,  filed  January  20,  2000. 
 10  Waiver  Request. 
 11  Northeast  Cellular  Telephone  Co.  v.  FCC,  897  F.  2d  1164,  1166  (D.  C.  Cir.  1990). 
 12  See,  e.  g.,  Request  for  Review  by  Stephen-  Argyle  Central  School  District,  Federal-  State  Joint  Board  on  Universal 
 Service,  Changes  to  the  Board  of  Directors  of  the  National  Exchange  Carrier  Association,  Inc.,  File  No.  SLD- 
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 Commission  granted  a  waiver  of  the  FCC  Form  471  filing  window  for  certain  applicants  in  the  first  three  program  funding  years  that  mailed  their  applications  at  least  three  days  before  the 
 filing  deadline,  or  the  day  before  via  guaranteed  overnight  courier.  13  Newtown  states  that  it  was  “unable  to  resolve”  with  Federal  Express  whether  the  carrier  picked  up  the  package  containing 
 the  application  in  a  timely  manner  on  January  18,  2000.  Because  Newtown  is  unable  to  present  the  evidence  necessary  for  granting  Newtown  relief  under  the  terms  of  Hardee  County,  we  are 
 unable  to  find  for  Newtown  in  the  instant  Waiver  Request 
 6.  In  light  of  the  thousands  of  applications  that  SLD  reviews  and  processes  each  year,  it  is  administratively  necessary  to  place  on  the  applicant  the  responsibility  of  complying  with  all 


 relevant  rules  and  procedures.  14  Thus,  in  order  for  the  program  to  work  efficiently,  the  applicant  must  assume  responsibility  for  timely  submission  of  its  application  materials  if  it  wishes  to  be 
 considered  within  the  window.  Here,  Newtown  fails  to  present  good  cause  as  to  why  it  could  not  timely  file  its  application.  We  therefore  must  deny  the  Waiver  Request. 


 7.  ACCORDINGLY,  IT  IS  ORDERED,  pursuant  to  authority  delegated  under  sections  0.91,  0.291,  1.3,  and  54.722(  a)  of  the  Commission's  rules,  47  C.  F.  R.  §§  0.91,  0.291,  1.3, 
 and  54.722(  a),  that  the  Waiver  Request  filed  by  Newtown  Public  Schools,  Newtown,  Connecticut,  on  March  30,  2001  IS  DENIED. 


 FEDERAL  COMMUNICATIONS  COMMISSION 


 Mark  G.  Seifert  Deputy  Chief,  Accounting  Policy  Division 
 Common  Carrier  Bureau 


 228975,  CC  Docket  Nos.  96-  45  and  97-  21,  Order,  16  FCC  Rcd  15,  879  (Com.  Car.  Bur.  2001)(  denying  waiver  request  where  application  was  untimely  due  to  blizzard). 
 13  See  Request  for  Review  by  Hardee  County  School  Board  et  al.,  Federal-  State  Joint  Board  on  Universal  Service, 
 Changes  to  the  Board  of  Directors  of  the  National  Exchange  Carrier  Association,  Inc.,  CC  Docket  Nos.  96-  45  and  97-  21,  Order,  DA  01-  2978  (Com.  Car.  Bur.  rel.  December  21,  2001)  (Hardee  County). 


 14  See  Request  for  Review  by  Anderson  School  Staatsburg,  Federal-  State  Joint  Board  on  Universal  Service,  Changes 
 to  the  Board  of  Directors  of  the  National  Exchange  Carrier  Association,  File  No.  SLD-  133664,  CC  Docket  Nos.  96-  45  and  97-  21,  Order,  15  FCC  Rcd  25610  (Com.  Car.  Bur.  2000)  para.  8  (“  In  light  of  the  thousands  of  applications 


 that  SLD  reviews  and  processes  each  funding  year,  it  is  administratively  necessary  to  place  on  the  applicant  the  responsibility  of  understanding  all  relevant  program  rules  and  procedures.”). 
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