If the FCC is going to roll funds from past years into the fund for 2008-2009, it's past time to do so. Rolling over funds after the application window is unfair to applicants. The FCC should make rollover decisions before the window opens.
Even better, use extra funds to pre-fund Priority Two for the following year. Under my scheme, the FCC would just bank any leftover funds until the opening of the 2009-2010 filing window next year. At that point, they make an educated guess as to where the denial threshold will be, and set it at that level. Then pay Priority Two requests to all applicants down to that level using the rollover (and some of the 09-10 funds if their estimate was off).
Imagine if Priority Two funding were not a crapshoot. It could happen if the FCC were willing to take a bold step.
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