E-rate getting stronger
I've posted a couple of times lately about my feelings on the spelling of "E-Rate." Well, things seem to be taking another turn that I don't like. I always say "the E-Rate," as in: "The E-Rate is the greatest thing since sliced bread." But I'm seeing the "the" omitted more often.
Today I saw it in an old
post by the Education Director of the National Broadband Plan. He said, "Thanks to E-Rate, virtually all our schools and libraries are connected." [Not at all true: the E-Rate has largely bypassed libraries and private schools, but that's another rant.] It also appeared in the FCC's
Community Use Order: "In this order, the Commission waives ... rules that currently discourage public use of resources funded by E-rate." (Usually, the FCC uses the term "the E-rate program," which finesses the question of whether "E-rate" is anarthrous.)
The vanishing definite article is common government-speak. For example, Peace Corps employees don't call it "
the Peace Corps." They say things like, "I work for Peace Corps," which sounds odd to anyone who doesn't work for Peace Corps. Listen to government employees talk about their agencies and programs, and you'll notice the definite article disappearing often.
The
Cambridge Grammar of the English Language calls a proper noun which doesn't require an article a "strong proper noun." So at least in one way, E-rate is getting stronger.
Tech Plan, Schmech Plan
I've said before that the E-Rate program
should not require a tech plan in order to get funding.
Inconsistent tech plan rules cause unnecessary denials. The tech plan requirement
discourages library and private school participation in the program. For most applicants, the only time they look at the plan is every 3 years, when the rules say they have to refresh the plan.
So why did I spend time even scanning the draft of the
National Educational Technology Plan? I guess I always hope that something significant will be in there.
Of course I read it like the dog in the old Far Side comic about what dogs hear when we talk to them. To me, it's just "Blah blah blah E-Rate blah blah blah."
So what jumped out of the blah-blah-blah?
First of all, the USDOE consistently using the spelling "E-Rate." Huzzah! Another one on my side of the
great E-Rate/E-rate debate.
On page 54, the USDOE goes off on a little anti-CIPA rant: "this requirement creates barriers to...rich learning experiences." The rant is expanded on in the sidebar on page 55. I couldn't agree more, but I'm surprised to hear the USDOE say it.
Otherwise, the E-Rate (with a capital "R") gets a couple of nice mentions (pages 60 and 62), but isn't much discussed.
Give USAC 200 points for the Extension
If you're reading this blog, surely you are enough of an E-Rate junkie to already know that the
filing window has been extended until February 19th.
I'm all for that. As
I've said before, I think a later window closing is a good thing for the program.
Silver lining a mirage
Those of you have been reading this blog for a while know
I hate the 2-in-5 rule. Then,
I found a tiny little silver lining. Well, turns out it was just a mirage.
See, there used to be a rule that applicants had to "have reasonable plans to use all of the network drops within two years." But since the 2-in-5 rule basically means you can only get network drops every 3 years, the rule was softened from "two years" to a "few years."
Only now I find out the rule wasn't changed, only obfuscated. The "few years" was just a bit of fog covering the "two years" rule, which is still the law of the land. The
Frankenstein-and-NOMAD-get-a-time-machine case that I've been working on for a year and a half is finally getting down to dollars and cents, and when push came to shove, the decree was that all drops had to be used within two years.
So can I count this as one of the many
secret rules? It used to be public (and can be found on an
old training slide), but now you can only learn about it when you've been stuck by the pointy end of it.
OK, the Form 470 season, I can't wait for improvements to the online form. The page that's getting my goat this year: Block 4, Item 16.
First goatgetter: every time I review the page, I have to recheck the radio button signifying that there are no ineligible entities. Once I select it, shouldn't it stay selected unless I change it?
The other one is that I have to scroll past 50 rows where I can put in area codes and exchanges. Are there any applications that need 50 rows? California only has 37 area codes. I'd guess that only a very small percentage of applicants use more than 3 rows. Can we just have 5 rows and an "add more rows" button?
Brief hopes dashed
I got my hopes up when I saw that the FCC had published an
addendum to the
Eligible Services Order released a couple of weeks back.
Maybe they heard the collective "HUH?!" issued when we all read the "unbundled warranty" rules in paragraph 28, and revised the guidance?
Nope, they're just renumbering some misnumbered paragraphs.
So we're almost a quarter of the way into the filing window, and I have yet to hear of anyone who understands what the rules are on hardware maintenance.
E-rate by any other name
I just can't give up on capitalizing the "R" in "E-Rate." As faithful readers know, after chastizing others for their spelling of our beloved program, I
recently noticed that my spelling is not the same as the FCC's.
So of course I'm thinking that the FCC is wrong, and I set out to prove it. So I thought I'd start with the
Telecommunications Act, which created the E-Rate (OK, E-rate, whatever). Alas, "E-rate" does not appear in the law. So I went to the
regs: again, bupkus.
Well, what about the founders of the E-Rate? Well, it was called the "Gore Tax," so I thought I'd see how the inventor of the Internet spelled it. Alas, I could not find any writings from Gore using the term "E-Rate."
The E-Rate was the result of the Rockefeller-Snowe-Exon-Kerrey Amendment, so let's see how those senators spell it. The first 10 documents that Google listed from Rockefeller's Web site with "E-Rate" in them included 7 using "E-Rate" and 3 using "E-rate." Damn, Senator, make up your mind. The "E-rate" documents were all 2001 or earlier, but there were some early "E-Rate" spellings, too.
On to Senator Snowe. Google found only 3 documents on her Web site (understandable that a Republican does not want to trumpet her involvement with this program). All "E-Rate." Way to go, Sen. Snowe!
Senator Exon? Never heard of him. (How much did the Exxon lobbyists have to pay him to change his last name? And why didn't they pay him a little more to add the second x?) I can't find anything written by him with "E-Rate" in it.
Senator Kerrey. I only found two documents. One used "E-rate," the other "e-rate." Booooo!
Well, at least I'm not the only one who's been spelling it "E-Rate," but I can't say that the will of Congress was to have that "R" capitalized.
Maybe if I file an appeal with the FCC, asking them to capitalize the R? They seem willing to grant just about any appeal these days. Nah, they'd probably just grant me a waiver with that "narrow focus" paragraph at the end, and USAC would interpret it to mean that any documents that capitalize the R should be denied.
Did I say that out loud?
