On August 3, 2021, the Wireline Competition Bureau (“WCB”) released a Public Notice finalizing the application filings, procedures, cost catalog, and replacement list for the Secure and Trusted Communications Network Reimbursement Program. The Public Notice adopts the procedures as described in the May 24, 2021 Public Notice seeking comment, a summary of which is described below. In addition, a handful of notable changes and clarifications were made, including:
Filing Window –WCB currently has a target date of late October for opening the filing window; the actual date will be announced in a future PN. WCB anticipates that the fling window will run for at least 60 days, and potentially longer.
· Eligibility Verification – as proposed, WCB will utilize FCC Form 477 data to determine whether a provider is eligible (i.e. has 10 million or fewer customers and is providing advanced telecommunications services).
· Cost Estimates –WCB clarifies that providers who may wish to upgrade their equipment may still receive a reimbursement for the cost of a comparable replacement, but will be responsible for any additional cost for the upgrade above the cost of the comparable replacement. Individuals seeking reimbursement for upgraded equipment will be required to provide price quotes for the comparable replacement with their application; they may not rely on the cost estimates in the catalog.
· Reviewing Applications –WCB adopts the review process with minor clarification that a 15 day opportunity to cure starts on the day staff notifies the applicant by email. Requests for additional information are distinct from any 15 day opportunity to cure.
· Reimbursement Claims Requests –WCB will allow participants to file reimbursement claims requests even when the amount requested exceeds the amount allocated to the participant until the deadline for filing claims has expired. WCB also clarifies that costs associated with preparing applications may also be eligible for reimbursement. All reimbursement claims must be filed no later than 120-days following the expiration of the removal, replacement, and disposal term, and at least one claim must be submitted within one year of the approval of a participant’s application.
· Removal, Replacement, and Disposal Term –WCB will require participant to remove, replace, and dispose of equipment within one year of the initial disbursement of funds. Participants must file to receive their initial disbursement within one year of receiving funding allocation approval. Extensions of the program will be granted if the WCB determines the statutory requirements have been met.
In addition, WCB adopted a final Catalog of Eligible Expenses and Estimate Costs, to guide applicants in determining their estimated costs, and a final List of Categories and Suggested Replacement Equipment and Services, to guide providers in removing, replacing, and disposing of covered equipment.
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