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Friday, September 15, 2006

Another mass waive

Another FCC ruling, another massive wave of waivers. Only 128 applications covered this time, for late or misfiled 486es. Two reasons I'm feeling happy.

First, Paragraph 8 requires something I've been asking for: the SLD has to notify applicants that a 486 is overdue, and give them a chance to file it. It's always been a sore point with me that the SLD can see in its database that a 486 is coming due, or is overdue, and they don't do anything to let applicants know they're about to lose funding. Some state E-Rate coordinators, like Julie Tritt Schell over in PA, were notifying applicants at risk, and I was doing it for NJ schools when I had the time, but it's nice that the SLD will be doing it for all applicants.

Second, it's made me nostalgic. This decision grants the first appeal I ever wrote (back in 2004, for a school that was in a mess when I arrived). At least I think it's the first. It certainly looks amateurish enough. And I remember when we filed it, I told the applicant not to expect anything, because the FCC never grants appeals. How times have changed.

My favorite parts of the decision: footnotes 35 and 36.

#35 makes it clear that as long as an applicant is making its best effort to respond to the SLD, the 15-day response time is to be extended. The SLD has always been lenient, but it's good to have the FCC explicity state that the SLD is not obligated to deny applicants on the 16th day.

#36 removes a worry that I had: that the FCC was going to grant these giant waivers, then go back to the old "deny, deny, deny" mentality. This footnote implies (I think) that the FCC will continue to give waivers.

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