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Commission Document Attachment


Federal Communications Commission

DA 14-263


Long-Form Application Filing Instructions

This attachment provides instructions for each winning bidder in Auction 902 to complete and
file an application for Tribal Mobility Fund Phase I support, known as a long-form application,
using FCC Form 680.1



Each winning bidder must submit its long-form application (FCC Form 680) electronically, via
the FCC Auction System.

All long-form applications for Auction 902 must be submitted and
confirmed prior to 6:00 p.m. Eastern Time (ET) on Friday, April 4, 2014.

A winning bidder
that fails to submit a long-form application by this deadline and fails to establish good cause for
any request for a late submission shall be deemed to have defaulted and will be subject to the
auction default payment set forth in section 1.21004.2
We remind winning bidders that no application for Tribal Mobility Fund Phase I support will be
considered unless it has been filed timely in an acceptable form.3 Each application must contain
all of the information set forth in section 54.1005(b)(2) of the Commission’s rules.4 Unnecessary
sensitive information, such as Taxpayer Identification Numbers or Social Security Numbers,
should not be included in the long-form application or any attachments. Applicants may request
that submitted information not be made routinely available for public inspection following the
procedures set forth in section 0.459 of the Commission’s rules.5 Any such request must be
included as an attachment to the applicant’s FCC Form 680, identify the specific information to
which the confidentiality request applies, and include a tailored, redacted version of the
information that can be made public. Because the required information bears on each applicant’s
qualifications, confidentiality requests will not be routinely granted.6
Applicants may make multiple changes to their long-form applications until the close of the filing
window. However, they must press the


button in the FCC Auction System any time
changes are made for those changes to be submitted and considered by the Commission.


Minimum Software Requirements

The following software, at a minimum, is required to use the FCC Auction System:
 Web Browser, either of the following is recommended:

Microsoft® Internet Explorer 8.0 or higher

Mozilla® Firefox® 3.5 or higher
 PDF Viewer: Adobe Acrobat Reader 5.0 or higher (available at" title="">
 Minimum Screen Resolution: 1024 x 768

1 See 47 C.F.R. § 54.1005(b) (requirements for Tribal Mobility Fund Phase I long-form application for
2 47 C.F.R. § 1.21004 (auction default payment of five percent of total winning bid).
3 See 47 C.F.R. § 54.1005(b)(3).
4 47 C.F.R. § 54.1005(b)(2).
5 47 C.F.R. § 0.459.
6 47 C.F.R. § 0.459(a).

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Currently, the Apple® Mac OS® is not supported.


Logging On

To submit or edit a long-form application (FCC Form 680) online, an applicant should open its
web browser and navigate to either" title=""> (primary location) or" title=""> (secondary location). Once on the FCC Auction System page, the
applicant must log in using the same applicant FCC Registration Number (“FRN”)7 and password
that was used in creating and filing the applicant’s short-form application (FCC Form 180). On
the My Auctions page, select the

Click here to file FCC Form 680

link under the Connect
America Fund section. This produces the Auction Application Manager page. At the bottom of
the page select the link for Auction 902 under

Create New Long-Form Applications


or Modify Existing Long-Form Applications

. Only an entity that has been identified as a
winning bidder in this Public Notice will be able to create a new long-form application or review
or modify an existing long-form application.


Application Filing Instructions

The FCC Auction System will prefill certain categories of information from the winning bidder’s
short-form application into its long-form application: Applicant Information, Winning Bids,
Agreements, and Ownership. You should be aware, however, that the applicant is solely
responsible for ensuring that all information contained in a submitted application is accurate,
updated, and complete.
Please note that any attachments that an applicant may have submitted with the short-form
application will NOT be carried over to the long-form application. To the extent that any
information required in the long-form application was provided in an attachment to a winning
bidder’s short-form application, and no FCC Form 680 data field exists to provide that
information, such information should be provided as an attachment to the winning bidder’s long-
form application. If a FCC Form 680 data field is provided, responsive information must be
inserted in the proper data field of the form, not in an attachment. Attachments that apply to the
entire application, and are not specific to any particular Winning Bid, can be uploaded at any
screen by clicking on the


link at the top of the screen.

Applicant Information Screens

Each applicant must carefully review its applicant information, including its name, address, legal
classification, and contact information, all of which will have been prefilled from its short-form
application. You must review information in this section carefully to confirm that it is complete
and accurate. If there have been any changes or corrections to the applicant’s information, the
applicant should answer the appropriate questions and verify the information before continuing to
the next section.

Winning Bids Screens

The Winning Bids screens are prefilled with the applicant’s winning bid(s) (called an item in the
FCC Form 680) that the applicant won during Auction 902. In this series of screens, an applicant

7 An FRN is a 10-digit number that is assigned to a business or individual that has registered with the FCC.
It is used to uniquely identify an individual or business in all transactions with the FCC.

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must, for each of its winning bids, indicate whether the applicant will provide 3G or 4G service
with its Tribal Mobility Fund support and upload the required attachments.
3G/4G Selection
On the first screen in this series, Select A Service Type, an applicant must indicate for each item
whether 3G or 4G service will be provided by checking the checkbox beside the item(s) and then
clicking the appropriate

Mark as 3G


Mark as 4G

button at the bottom of the page. If an
applicant wishes to select the same service for all of its winning bids displayed on the page,
clicking the Select All link at the top of the column and the appropriate button will mark all of its
winning bids on that page as either 3G or 4G.

Winning Bid Attachments

As previously described in this Public Notice, each winning bidder must submit a minimum of
five separate attachments for each winning bid: (i) Eligible Telecommunication Carrier (ETC)
designation, (ii) project description, (iii) spectrum access, (iv) letter of credit (or commitment
letter), and (v) tribal engagement notification.
The second screen in this series is divided into two sections: Upload Item Attachment and Attach
Files to Winning Bids
. Use the


dropdown field to select one of the valid item attachment
types: Commitment Letter, ETC Designation, Letter of Credit, Opinion Letter, Project
Description, Spectrum Access, Tribal Engagement, or Waiver. Click the


button to select
the file from your computer or network. Enter a brief description of the attachment in the text
box then click the

Upload File

After you have uploaded a file, you can attach it to one or more Winning Bids. To do this, select
a file from the Uploaded Files list box on the left side of the page. Then, click the


beside the Winning Bid(s) you would like to attach the file to or, if the file attachment applies to
all of the Winning Bids displayed on the page, click the

Attach All

link to attach the file to all
displayed Winning Bids. Winning Bids associated with the selected file will be displayed in the
Selected Winning Bids table on the right side of the screen. To detach a file from a Winning Bid,
click the


link next to the Winning Bid(s) in the table, or click the

Detach All

link to
detach it from all Winning Bids.

Important Notes Regarding Winning Bids Attachments:

 At the initial long-form application filing, you must submit either a written commitment
letter from the bank that will be issuing the letter of credit (in which case, you would use
file type Commitment Letter for the attachment) or a letter of credit accompanied by the
bankruptcy opinion letter from outside counsel (in which case you would use file type
Letter of Credit and Opinion Letter for the attachments). If you submit the commitment
letter at your initial long-form application filings, you will then need to upload the letters
of credit and opinion letter when the Commission issues a public notice identifying the
winning bidder as authorized to receive Tribal Mobility Fund support.

8 If you are uploading different attachments of the same type (e.g., different ETC attachments for winning
bids in separate geographic areas), we encourage you to enter a different brief description for each
attachment of that type to help distinguish the different attachments.

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When uploading letters of credit, you must upload the letter of credit
corresponding to the appropriate winning bid. You should not attach each letter
of credit to every winning bid.

You may utilize one bankruptcy opinion letter for all winning bids. Such letter
must be attached to each winning bid. The opinion letter must list all of the
winning bids to which it applies, either in the body of, or as an attachment to, the
 A Tribal Engagement attachment is required for all winning bids. For a limited number
of eligible areas, there may be no Tribal government associated with certain eligible areas
covered by a winning bid. In such case, the applicant should upload a Tribal Engagement
attachment containing a brief explanation of the particular facts for the areas covered by
that winning bid.
 When uploading attachments, you may use a variety of file formats, including Microsoft®
Word, WordPerfect 5.x or later, Adobe® Acrobat® PDF, and ASCII text. Applicants
must, however, verify that the file contains all attachment information, and files may be
no larger than 10 Mb and must not be password-protected. Graphics files (e.g., .bmp,
.tiff, .jpg) and spreadsheets (e.g., Excel, Lotus) are supported but not recommended.

Winning Bids Summary

The third and final screen in the Winning Bids series is the Winning Bids Summary page, which
lists each Winning Bid and provides additional information as shown below. This information
can be sorted by any column, with the exception of Attachments, in ascending or descending
order by clicking on the column title.

Item Name

. This identifies the applicant’s individual winning bid(s) by name. Also
displays the county and state where the item is located. Items cannot be deleted or

Tribal Bidding Credit

. Percentage of credit is displayed if applicant had selected it on its
short form application. This selection cannot be deleted or modified.
3G/4G. Type of mobile service, either 3G (third generation as defined by section
54.1006(a)) or 4G (fourth generation as defined in section 54.1006(b)).


. To help you keep track of uploaded files associated with each item, a


link is displayed for each item showing the number of files that have been attached
for the item. Clicking on the link will display a sub-window where you can see the
attachment type, description, and upload date and time. Clicking on the description name
allows you to view the attachment. Click on the


link to close the sub-window.


Status of each winning bid will be displayed after the long-form application is
processed by Commission staff.


. This column displays an error indicator with one or more of the following icons:
Indicates that you have not selected a mobile service type (3G or 4G) for that
Indicates that you are missing one or more of the required attachments for
that item.

Agreements Screen

In the Agreement section, the agreement information that was provided on the winning bidder’s
FCC Form 180 will be prefilled into its FCC Form 680. You may make changes to ensure that
the winning bidder’s agreement information remains complete and accurate. An applicant can
edit any information that was pre-filled and/or add additional agreements if needed.

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Ownership Information Screens

Similarly, the ownership disclosure information that was provided on the winning bidder’s
FCC Form 180 will be prefilled into its FCC Form 680. Specifically, information in the
FCC Form 180 data fields for the winning bidder’s Disclosable Interest Holders (DIHs) and
FCC Regulated Businesses (FRBs) will appear in the FCC Form 680. An applicant can edit any
information that was pre-filled and should make changes to ensure that the winning bidder’s
ownership information remains complete and accurate.
A winning bidder must comply with the ownership disclosure requirements set forth in section
1.2112(a) of the Commission’s rules, which is the same standard that was to be followed in
completing the short-form application.9 We provide in section I.C.7., below, guidelines for
satisfying the ownership disclosure requirements.
You should refer to the discussion in this Public Notice concerning the possible consequences of
certain kinds of changes.10 While an applicant will be permitted to make minor modifications to
its application, major modifications will result in a denial of the application.11 In such event, the
applicant also would be subject to an auction default payment for its winning bid(s).12
To add a DIH or FRB, click the


button and the system will enable the appropriate fields for
you to supply the additional information. You may also delete DIH and FRB entries. An
applicant may add an attachment to its application to describe or explain any such changes. As
mentioned above, any attachments that had been submitted in connection with the ownership
disclosures on the FCC Form 180 will not be carried over automatically to the FCC Form 680.


The Summary screens summarize information applicants have provided in previous screens,
offering an overview of an applicant’s FCC Form 680 to help locate specific information. These
screens will appear prior to the Certify and Submit screens, in order to permit the applicant to
review all the information entered in previous screens and to provide an opportunity to check for
certain inconsistencies or omissions in the information within the FCC Form 680.
The first Summary screen, the Summary Overview screen, lists the first four series of screens in
the application and provides a


button to access each one.



for Applicant Information produces a Detail for Applicant
screen showing the information entered for each data entry field. To change
any data item, the applicant should click the


icon for the relevant data field.



for Winning Bids takes the applicant to the Winning Bids



for Agreements takes the applicant to the Agreements screen
discussed above in the Agreements section.

9 47 C.F.R. §§ 1.2112(a), 54.1005.
10 See section V.D., “Maintaining Accuracy of Information.”
11 47 C.F.R. § 54.1005(b)(3).
12 47 C.F.R. § 1.21004.

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for Ownership takes the applicant to the View/Edit Ownership
Disclosure Information
screen discussed above in the Ownership section.
Clicking on the


button initiates an automated check of the application. If the
automated check encounters certain inconsistencies or omissions in information within the
FCC Form 680 that must be corrected before submitting the application, the inconsistency or
omission will be listed in an Error box at the top of the screen. To correct one of these errors,
click its corresponding


button. In addition, if the automated check encounters certain
apparent inconsistencies or omissions that might render the application incomplete or deficient if
the application is submitted with current information, the apparent error will be listed in a
Warning box. To revise the information related to the apparent inconsistency or omission, click
its corresponding


Each applicant is solely responsible for providing complete and accurate information in its
FCC Form 680. The automated check is provided to assist applicants in completing the
FCC Form 680. However, the automated check cannot be relied upon to determine whether the
information provided is complete or accurate. The automated check may not catch all errors and
applicants cannot rely on the automated check to determine the completeness or the accuracy of
submitted information.
If the automated check does not encounter certain inconsistencies or omissions, a box will appear
displaying the message “

No Errors found - You may continue to Certify and Submit.

Applicants may then click the



Certify and Submit

The Certify and Submit screen is the fifth and final screen in FCC Form 680. In this screen,
applicants provide certifications required of all winning bidders in the Tribal Mobility Fund
Phase I auction.13
The Certify and Submit screen lists the certifications required of all winning bidders in the
Commission’s Tribal Mobility Fund Phase I auction and requests that the applicant’s certifying
official be identified and sign the application.

Who Can Certify.

A long-form application may be certified by an authorized representative of
the applicant, who has read the form’s instructions and certifications, and can certify that the
contents of the application and its attachments are true and correct. For example, the long-form
application may be certified by a partner, if the applicant is a partnership; or an officer, director,
or duly-authorized employee, if the applicant is a corporation; or by a member who is an officer,
if the applicant is an unincorporated association. A duly-elected or appointed official who is
authorized to do so under the laws of the applicable jurisdiction would certify on behalf of an
eligible government entity.
Applicants are reminded that submission of an FCC Form 680 constitutes a representation by the
certifying official that he or she is an authorized representative of the applicant and has read the
form’s instructions and certifications, and that the contents of the application, its certifications
and any attachments are true, complete and correct. Submission of a false certification to the
Commission may result in a denial of Tribal Mobility Fund support, an auction default, and/or

13 See 47.C.F.R. § 54.1005.

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penalties, including monetary forfeitures, license forfeitures, ineligibility to participate in future
auctions, and/or criminal prosecution. A change of certifying official is considered a major
change of the long-form application and will not be permitted after the application filing deadline.
Additional details about the certifications can be found in this public notice.14
Once the Certify and Submit screen has been filled out, the application may be submitted by
clicking on the


After the application has been submitted, a confirmation screen will be displayed that states the
submission time and date, along with a unique file number. Applicants should print a copy of the
confirmation page for their records. They may then view and print copies of their submitted
applications by clicking on the


Long-form applications for Auction 902 must be submitted and confirmed prior to 6:00 p.m. ET

Friday, April 4, 2014

. Late applications or unconfirmed submissions of electronic data will
not be accepted.

Guidelines for Reviewing and Updating Ownership Information

You should use the following guidelines when reviewing the application’s ownership information
for accuracy and completeness. These guidelines are similar to those used in completing the
short-form application because the ownership disclosure requirements set forth in section
1.2112(a) of the Commission’s rules govern both the short- and long-form applications.
In the Ownership screens, applicants will provide information regarding parties with control or
ownership interests in the applicant that must be disclosed pursuant to Commission rules.15
Commission rules also require the disclosure and description of FCC-regulated businesses that
are owned 10% or more by the applicant or by parties with certain ownership interests in the

Disclosable Interest Holders and FCC-Regulated Businesses

Section 1.2112(a) of the Commission’s rules list the interest holders in the applicant that must be
disclosed in FCC Form 680.17

Applicants must report holders of both direct and indirect

Section 1.2112(a)(7) lists the FCC-regulated business entities, or applicants for an FCC license,
that must be disclosed in FCC Form 680.18
The initial Ownership screen enables the applicant to add information regarding either a
disclosable interest holder or the FCC-regulated businesses in which either the applicant has an
ownership interest of 10% or more or parties with 10% or more ownership interest in the
applicant have an ownership interest of 10% or more. Each screen will specify the information

14 See section V.C., “Long-Form Application (FCC Form 680) Certifications.”
15 47 C.F.R. §§ 1.2112(a), 54.1005(b)(2).
16 Id.
17 Section 54.1005 requires the disclosure on the long-form application of information as set forth in section
1.2112(a). 47 C.F.R. §§ 1.2112(a), 54.1005.
18 47 C.F.R. § 1.2112(a)(7).

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that the applicant must provide. Please note the following with respect to particular information

If an application includes one or more disclosable interest holders with indirect

ownership in the applicant,19 the application must include an attachment describing
the relationship between the indirect interest holder(s) and the applicant.
attachment should provide an overview of the ownership chain that links the indirect
owner(s) to the applicant, e.g., indirect owner X owns 50% of holding company Y;
indirect owner Z owns 50% of holding company Y; and holding company Y owns 100%
of the applicant.20 One attachment connecting all indirect owners to the applicant is
sufficient. Applicants should not provide separate attachments for each indirect owner.
An overview of the ownership connections is sufficient. The attachment should not
duplicate all the detailed information already provided in the data fields of the
FCC Form 680. Also, as noted above, the Indirect Ownership attachment provided in an
applicant’s short-form application will not automatically be pre-filled on the winning
bidder’s long-form application. Therefore, if the applicant uploaded an Indirect
Ownership attachment on its short-form application, it should upload the attachment to its
long-form application, updated as necessary.
 The “Percent of Interest Held in Applicant” should reflect the disclosable interest
holder’s aggregate ownership interest in the applicant (both direct and indirect). In some
cases, e.g., circumstances where there is joint ownership or indirect ownership resulting
in different owners sharing the same ownership interests, the sum of all the percentages
held by disclosable interest holders may exceed 100%. In other cases, a disclosable
interest holder may have a 0% ownership interest in the applicant.
 FCC-regulated businesses in which the applicant has a direct interest of 10% or more can
be entered from the initial Add Ownership Disclosure Information screen. FCC-regulated
businesses in which a disclosable interest holder has a direct interest of 10% or more can
be entered from the Add FCC Regulated Business screen in the series of screens for
entering information about a disclosable interest holder.
 When adding an FCC-regulated business, “Percent of Interest Held” refers to the percent
of interest held directly by the applicant or disclosable interest holder, as applicable, in
the FCC-regulated business. FCC-regulated businesses in which the applicant or
disclosable interest holder has an indirect interest need not be reported in the
FCC Form 680.
 To simplify filling out the FCC Form 680, applicants can click on the

Select Business(es)

Already Submitted

link when entering an FCC-regulated business previously entered as
an FCC-regulated business for the applicant or another disclosable interest holder. When
doing so, be certain to enter the “Percent of Interest Held” in the FCC-regulated business
by the current party, either the applicant or the disclosable interest holder, with respect to
which the FCC-regulated business is being entered.

19 47 C.F.R. § 1.2112(a)(6).
20 Id.

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View/Edit Ownership Disclosure Information

The View/Edit Ownership Disclosure Information screen summarizes ownership information
already entered in the FCC Form 680, either automatically from the winning bidder’s
FCC Form 180 or directly by the applicant, and provides links enabling existing information to be
revised and additional information to be added.
Existing ownership information is divided into two groups:

Disclosable Interest Holders of this Applicant21

FCC-Regulated Businesses of this Applicant
To view the detailed information submitted regarding the applicant, a disclosable interest holder
or FCC-regulated business, click on the relevant party’s name. To delete existing information or
add a new entry in one of the categories, click on the relevant link. This screen also provides a
link enabling applicants to add an FCC-regulated business directly to an existing disclosable
interest holder, without needing to reenter the disclosable interest holder’s information.



For technical assistance with using FCC software, contact the FCC Technical Support Hotline at
(877) 480-3201, option nine; (202) 414-1250; or (202) 414-1255 (TTY). The FCC Technical
Support Hotline is available Monday through Friday from 8 a.m. to 6 p.m. ET. All calls to the
FCC Technical Support Hotline are recorded.
Paperwork Reduction Act Approval: The FCC Form 680 was assigned control number 3060-
1166 and was approved, as revised, by the Office of Management and Budget on April 16, 2012.

21 Existing ownership information in a Disclosable Interest Holder (DIH) entry includes the FCC Regulated
Business (FRB) entries previously entered for that DIH, if any.

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