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Monday, October 29, 2007

All in good time

It's official: this year's filing window will open on Nov. 7th and close on Feb. 7th. The USAC board approved a January 24th closing, but thank goodness, the closing has been returned to early February.

93 days! I think that's the longest window ever. Poor Mel (Blackwell): he wants a shorter window, and we're going the opposite direction. Of course, what Mel really wants is an earlier closing. In this case, I hope he doesn't get what he wants.

I, on the other hand, want a later closing for two reasons. The first is that forcing people to sign contracts for technology purchases at least six months before the purchase is made just isn't cost-effective. And forcing people to sign contracts and certify "secured" funding so far in advance of budget approvals puts applicants in an untenable position.

The second reason is based on one of the laws (well, one of my laws, anyway) of organization: a process will expand to fill the time allotted to it. So if the window closes at the end of April, the PIA process will shrink in order to process all those apps in two months. If the window closes in late December, the PIA process will expand to fill the extra weeks. So now let's have a show of hands: who wants an expanded PIA process? All right, I see a few hands up in the back, must be GAO or OIG observers. But I don't think even Catriona Ayer, the head of PIA, really wants to see the process go any further into the minutiae of funding requests.

Just imagine if PIA only had two months. I'll bet credits to navy beans that if your request was for Telecommunications Services, and less than $3,000 (which is about the median for the program), PIA review would consist of a spell-check. And you know what? The program wouldn't be any worse off: telecom is too highly regulated to be easily abused, and there's no point in trying to skim a percentage off $3,000. It's almost not worth it to do all the E-Rate paperwork for $3,000.

So the later the window closes, the more PIA will be forced to focus its effort on the areas that really deserve scrutiny, and leave in peace the 80% of applicants who just want a little help paying their measly phone bill.


  1. My law of organization, "a process will expand to fill the time allotted to it," is remarkably close to Parkinson's Law: "work expands so as to fill the time available for its completion." I didn't lift it consciously, but I don't want to get sued by Mr. Parkinson's estate, so I thought I'd mention that he said it first. His statement that it is a "commonplace observation" would weaken his estate's legal claim to the idea.

  2. And 8 years later, I got my wish! USAC has announced that the window for FY 2016-2017 will close April 29, 2016.

    And when thousands of unsuspecting applicants start their 471s in late April and discover that their locations didn't transfer over to EPC properly, and that the correction will take a couple of weeks, I expect the date to slide further.