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Wednesday, May 16, 2007

Chairman Martin replies

Well, now we have FCC Chairman Martin's answers to Rep. Markey's questions about the Universal Service Program. I already gave my answers. Let's look at Chairman Martin's. I'm going to paraphrase viciously.

1) Should Universal Service be exempt from ADA?
No. “At this time, Commission staff estimates that the universal service program can continue to operate as it does today without triggering an Antideficiency Act violation.”

2) Have recent appeal decisions gone too far? How can we clarify the rules?
The FCC decisions are simplifying the process and directing USAC to do more outreach.

3) Should the poorest districts continue to get highest subsidies? Free telecommunications? Extra subsidies for high-bandwidth services?
Yes. No. Pass.

4) Do you support lifting the $2.25 billion/year cap?

Here's how I score his answers. Since this is an education program, I feel compelled to give him letter grades.
1) F The way the program works now is screwed up, and if you fix it, you'll trigger an ADA violation. If all applicants knew before the start of the funding year what level of funding they would receive, it would be an ADA violation. A violation is avoided only because many applicants don't get approval until 9 months into the funding year whether they're funded, and USAC is sitting on $1 billion in un-rolled-over funds. Not requesting a review from OMB is understandable, but telling Congress that the program doesn't need an exemption is just bad.

2) B+ I have to say, it's true that the program has gotten less confusing. PIA reviewers follow a script, and I have found their scripted responses more straightforward than in the past.

3) C+ If I were Chairman, I would have said that all the major cases of waste, fraud and abuse (WFA*) involve applicants with high subsidies, and that the highest discount percentages are too high. The Chairman tiptoed close to that by saying that the applicant co-pay was important in preventing WFA. If only he would say what the WFA Task Force said back in 2003: the 90% discount causes WFA.

4) B If the fund were uncapped, the Priority Two funding would go through the roof. As I said earlier, though, I'd like to see the cap just on Priority Two. Easy answer, though.

So I think that puts his average somewhere around a C, but only because there's no such thing as an F-- for that first answer.

* Am I the only one who finds it troubling that we E-Rate junkies have an acronym for waste, fraud and abuse?

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