Justification for Non-substantive Change Request

Federal Communications Commission

Explanation of Non-Substantive Changes to OMB Control Number: 3060-0806:

• FCC Forms 470 and 471

Purpose of this Submission: This submission is being made for several proposed non-substantive changes to an existing information collection pursuant to 44 U.S.C. § 3507. This submission seeks to make non-substantive changes by adding program certifications to the Schools and Libraries Universal Service Description of Services Requested and Certification Form 471 (E-Rate FCC Form 471) and make non-substantive changes to certain fields in the Schools and Libraries Universal Service Description of Services Requested and Certification Form 470 (E-Rate FCC Form 470) and E-Rate FCC Form 471. The FCC Forms 470 and 471 are contained in an online portal.

Background: On July 29, 2024, the Commission released a Report and Order and Further Notice of Proposed Rulemaking (WC Docket No. 21-31, FCC 24-76; 89 FR 67303, August 20, 2024) (2024 Wi-Fi Hotspots Order) finding that the off-premises use of wireless mobile Internet services and the concomitant Wi-Fi hotspot devices serves an educational purpose and are eligible for E-Rate support. In order to implement the findings in the 2024 Wi-Fi Hotspots Order, we seek to add off-premises Wi-Fi hotspots and services language to E-Rate FCC Forms 470 and 471, and add certifications of compliance to the E-Rate FCC Form 471 for schools, libraries, and consortium to certify that they are not receiving duplicative funding; will create and maintain an asset and service inventory; and will not use Wi-Fi hotspots or service as part of a one to one Wi-Fi hotspot initiative, nor will the Wi-Fi hotspots be purchased for future use, emergency use, or use in the case of theft, loss, or breakage.

Summary of Proposed Changes to the FCC Forms 470 and 471:

• We propose to add Off-Premises Category One – Hotspots Equipment and Services as a service type to the E-Rate FCC Forms 470 and 471.

• We propose to add a certification of compliance to the E-Rate FCC Form 471 for schools, libraries, and consortium to certify that they are not receiving duplicative funding.

• We propose to add a certification of compliance to the E-Rate FCC Form 471 for schools, libraries, and consortium to certify that they will create and maintain an asset and service inventory if they request off-premises hotspots and services.

• We propose to add a certification of compliance to the E-Rate FCC Form 471 for schools, libraries, and consortium to certify that they will not use Wi-Fi hotspots or service as part of a one to one Wi-Fi hotspot initiative, nor will the Wi-Fi hotspots be purchased for future use, emergency use, or use in the case of theft, loss, or breakage.

• The proposed changes will not increase the burden hours.

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