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Purchase & Implement

Form 470 Best Practices

As you put out your request for network upgrades, driving competition and flexibility will ensure that you can obtain better service without significantly increasing cost. In the pages linked below we outline some best practices we’ve seen amongst E-rate applicants for submitting a Form 470 to solicit competitive and flexible provider bids to upgrade their networks.

5 Tips for Filing Your 470

Download our E-rate Form 470 Checklist for a step-by-step guide with additional tips.

Make sure your narrative explains your requirements in detail.

If you are not attaching an RFP, the narrative field on the Form 470 is your only opportunity to describe what you are seeking in detail. Even a short paragraph can supply a vendor the necessary information they need to submit a complete proposal. More details about your narrative

Use the words “or equivalent.”

Specifying a particular model without being open to equivalent equipment by different manufacturers can be interpreted as stating a preference, which is a violation of E-rate’s fair and competitive bidding policies.

Note that if you intend to purchase off a state contract you may not have to file your own Form 470.

Please see advice on USAC website for more information.

You must comply with state and local procurement laws.

Do not assume that E-rate rules also satisfy these laws.

The service requests on the form MUST match the services the RFP is requesting.

If you are attaching an RFP to your Form 470.

Cat 1 & Cat 2 Best Practices

Category 1 Narrative Examples

The way your Form 470 narrative is written depends on if you are attaching an RFP. It is also important to know if you are required to write an RFP based on the services you are requesting.

Since you are writing an RFP, your Form 470 narrative does not need to be detailed. A simple sentence such as “See RFP for details.” is sufficient.

In the absence of an RFP, a well written Form 470 narrative is incredibly important. Below is some high-quality template language for your narrative if you are seeking leased lit fiber Internet access or WAN connections. As every district is different it is impossible to build a template that is “one size fits all”, so remember to adapt these to meet your own local needs and regulations or contact us for template language specific to your scenario.

Category 1 Form 470 guidance

There are a number of critical sections in the Form 470. Completing these sections in a way that gets you the best possible future outcome can make a significant difference in the value of your broadband investment.

SERVICE REQUEST SECTION & INPUT GUIDANCE

  • Ensure you select the appropriate function for the service your school district is seeking. A definition of these services has been provided.

    • Leased Lit Fiber (with or without Internet Access)
      • Point to point transport connection delivered over leased lit fiber
      • Internet access service delivered over leased lit fiber
      • Use your narrative to specify whether the request is for Internet access or point to point transport.
    • Internet Access & Transport Bundled (Non-Fiber)
      • Internet access service delivered over copper, wireless, or any type of non-fiber circuit
      • DO NOT use this for a fiber based Internet connection
    • Transport Only – No ISP Service Included (Non-Fiber)
      • Point to point transport connection delivered over copper, wireless, or any type of non-fiber circuit
      • DO NOT use this for any type of fiber circuit
    • Internet Access: ISP Service Only (No Transport Circuit Included)
      • Internet access service with no transport circuit
    • Leased Dark Fiber and Leased Lit Fiber
      • Use this for either a traditional dark fiber lease or an IRU
      • Automatically includes leased lit fiber request per competitive bidding rules
    • Self-Provisioned Network (Applicant Owned and Operated Network) and Services Provided Over Third-Party Networks
      • Automatically includes additional request for services required by competitive bidding rules
    • Network Equipment
      • Use this function to request Category 1 eligible network equipment necessary to place leased dark fiber or self-provisioning into service.
    • Maintenance & Operations
      • Maintenance and operations services for leased dark fiber or a self-provisioned network

This field is used to enter the physical quantity of the service you are requesting. In most cases it will be the quantity of circuits, except for the following services:

  • Internet Access: ISP Service Only (No Transport Circuit Included)- not applicable since there is no physical circuit with this service
  • Leased Dark Fiber – quantity of fiber strands
  • Self-Provisioned Networks – quantity of fiber strands
  • Network Equipment – number of sites you need network equipment for
  • Maintenance & Operations – number of circuits you need this service for

Enter the minimum bandwidth you require for this request. If you are unsure, a good guideline to use as a minimum is the 2014 FCC bandwidth goal.

Note: This field is not applicable for Leased Dark Fiber or Self-Provisioned service types. However, It is required for Network Equipment and Maintenance & Operations. In these cases, select the speed you are intending to light the fiber at on day one.

Enter the maximum bandwidth you will require within the life of the contract. If you are unsure, a good guideline to use as a maximum is the 2018 FCC bandwidth goal. EducationSuperHighway recommends you select a range of bandwidth speeds that will allow you to upgrade as district bandwidth demand grows.
Note: This field is not applicable for Leased Dark Fiber or Self-Provisioned service types. However, It is required for Network Equipment and Maintenance & Operations. In the case of Network Equipment, think about the expected life of the equipment and select a higher speed you would expect to upgrade to during this life cycle. For Maintenance & Operations, select the maximum speed you expect to have these connections operating at during the life of the service contract.

  • Enter the total number of schools and/or buildings that will be served by the services requested.

To ensure you can evaluate all costs equitably across any submitted bids, we recommend you select ‘Yes.’

INSTALLMENT PAYMENT PLAN & INPUT GUIDANCE

If you expect special construction charges associated with a service request, it is recommended you select ‘Yes.’

If you select ‘No’ then you will not have to complete the next two questions.

Using the two dropdown boxes, specify the range of years you would like for a payment plan. The first box is for the minimum and the second is for the maximum.

Select ‘Annual’ if you would prefer the payments to be in equal amounts billed once per year. Select ‘Monthly’ if you would prefer equal payments to be billed every month.

Category 2 Form 470 Guidance

Unlike Category 1, there is less guidance to provide on what to request on a Category 2 Form 470. Requirements are going to vary greatly from district to district. However, there is some guidance that can assist you regardless of what you are filing for:

  • If you select any specific manufacturer in the service request line, it will automatically include the words “or equivalent.” If you include language in a narrative or RFP specifying a manufacturer or model of equipment, make sure to include these words. Failure to do so will result in a denial or adjustment of your funding request.
  • In many states, structured cabling jobs are seen as a capital improvement project. Sometimes the laws for these projects are different from normal purchases, so make sure you understand all the requirements specific to your locale.
  • RFPs
    • USAC does not require an RFP for any Category 2 requests. You only need to write an RFP if:
      • Your state or local procurement laws require it.
      • You cannot adequately describe your needs within the 5000 character limit of the Form 470 narrative box.
    • If you are not going to write an RFP, then it is highly recommended you write a detailed narrative explaining your requirements and goals of your network upgrades. The narrative box has a limit of 5000 characters, which is more than enough to provide a detailed project explanation in most cases. See below for examples of common Category 2 scenarios.
  • For any requests that involve structured cabling, installation services, or managed internal broadband services, is highly recommended you include (at a minimum) a floorplan of each building with data closets labeled. See example 3 and 4 below.
  • According to USAC, the quantity field is meant to be a best guess PROVIDED that you have described what you are trying to accomplish with your network upgrade in detail. If a vendor determines that a higher quantity of equipment is required to meet your needs than what is noted on your Form 470, you are allowed to request it on your Form 471.

Disclaimer: EducationSuperHighway (ESH) is providing these practices for informational purposes only and not as legal advice. ESH is not licensed to practice law and cannot provide legal advice. This document is not intended to substitute for your judgment. You assume full risk and responsibility for the use of or reliance on these practices or any information you obtain from ESH. ESH does not guarantee that the practices will adequately meet all your needs, and you are solely responsible for your use of this information or any RFPs you issue. For example, ESH’s document likely will not, and ESH makes no representations or warranties that this document will, cover all of the state and local procurement rules that may apply to services your district requests bids for. By using these practices you agree that ESH is not liable for any consequences from such use. If you have any questions or concerns about the contents of your service requests you should obtain legal counsel.