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 non-substantive changes to an existing information collection pursuant to 44 U.S.C. § 3507. This submission seeks to remove program certifications that are no longer applicable in the Schools and Libraries Universal Service Description of Services Requested and Certification Form 471 (FCC Form 471). This submission also seeks to remove certain fields that are no longer applicable to the Schools and Libraries Universal Service Description of Services Requested and Certification Form 470 (FCC Form 470) and FCC Form 471. Additionally, a minor non-substantive change to the fields of the FCC Form 471 is made.

Background: On September 30, 2025, the Commission adopted the Hotspots Order on Reconsideration (WC Docket No. 21-31, FCC 25-62 (Hotspots Order on Reconsideration)) that rescinds the Report and Order and Further Notice of Proposed Rulemaking (WC Docket No. 21-31, FCC 24-76; 89 FR 67303, August 24, 2024) (2024 Wi-Fi Hotspots Order). Specifically, it removes the eligibility of E-Rate support for off-premises use of wireless mobile Internet services and the Wi-Fi hotspot devices needed to deliver the services. On the same date, the Commission issued a declaratory ruling (WC Docket No. 13-184, FCC 25-63 (2025 Declaratory Ruling)) reversing the eligibility of E-Rate support for Wi-Fi services on school buses. Consistent with the Hotspots Order on Reconsideration and the 2025 Declaratory Ruling, we seek to remove “Off-Premises Category One – Hotspots Equipment and Services; Bus Wi-Fi” as a service type from FCC Forms 470 and 471 and FCC Form 471 certifications of compliance that resulted from the 2024 Wi-Fi Hotspots Order. The FCC Form 471 certifications will be removed because they related to the now rescinded 2024 Wi-Fi Hotspots Order, (i.e., certification that there would be no duplicative funding for Wi-Fi hotspots and services; certification on the asset and service inventory list; certification on not using Wi-Fi hotspots or service as part of a one-to-one Wi-Fi hotspot initiative, and certification on not purchasing Wi-Fi hotspots for future use, emergency use, or use due to theft, loss, or breakage). Additionally, we make a minor, non-substantive change by adding a check box on E-Rate FCC Form 471, for applicants to select their invoicing method (FCC Form 472 Billed Entity Applicant Reimbursement (BEAR) Form or FCC Form 474 (Service Provider Invoicing (SPI) Form).

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

• We propose to remove Off-Premises Category One – Hotspots Equipment and Services; Bus Wi-Fi as a service type to the FCC Forms 470 and 471.

• We propose to remove certifications of compliance to the FCC Form 471 for schools, libraries, and consortium requesting off-premises Wi-Fi hotspots and services:

  • certification on not receiving duplicative funding.

  • certification on creating and maintaining an asset and service inventory if they request funding for off-premises Wi-Fi hotspots and services.

  • certification 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 due to theft, loss, or breakage.

• We propose to add a check box on FCC Form 471, for schools, libraries, and consortium to select the invoicing method (FCC Form 472 Billed Entity Applicant Reimbursement (BEAR) Form or FCC Form 474 Service Provider Invoicing (SPI) Form).

• The proposed changes will not increase the burden hours and no costs are associated with this information collection.

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