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Monday, February 25, 2008

Putting the "Power" in "PowerPoint"

Another FCC decision, another 8 appeals granted. But wait, one appeal was denied. Why? Because the applicant admitted that the service provider had: 1) advised the applicant in determining the types of services it needed and for which it would seek bids; 2) assisted the applicant in filling out the FCC Form 470; and 3) submitted the FCC Form 470 from the service provider’s office.

OK, that does smell bad, but here's what jumped out at me. In part, the denial was based on information that was given during the SLD's training in 2001. What!? Does this mean that I should have been taking notes during those skits?

Seriously, since when are those presentations authoritative? I have always treated those presentations as USAC's best understanding of the FCC's rules. For the FCC to quote one of the presentations seems to me to be the FCC following a USAC rule.

Also, none of the applicants or service providers were allowed to attend those training presentations. In 2001, USAC held "train-the-trainer" workshops, which could only be attended by something like 4 people from each state. And there aren't even any real handouts from those training sessions, only the PowerPoint slides. Were we really supposed to treat a bunch of PowerPoint slides as rules?

I'm all for limiting service provider involvement in the application process, but the FCC needs to do that by actually creating and publishing rules, not by stretching previous appeal decisions and citing USAC training slides. Even better, the FCC should bow out of the procurement regulation business, and let state law handle it.

Wednesday, February 13, 2008

Glass half full

Four letters from USAC today. Two on pink paper, two on blue paper. And wonder of wonders, the blue papers were in blue envelopes! Be still my beating heart. Does this mean all my RALs will come in blue envelopes? I'm not hopeful that this is a sign of things to come, though: the letters have the new 3-hole punch, but were not folded in half in a smaller envelopes, like the "Notification of Form 470 Posted but No Associated Form 471" letters were.

To compound the mixed signals, the pink letters came in a white envelope.

I may have to go back to my strategy of becoming a major Solix shareholder, just so I can force them to use color-coordinated envelopes. And I'd force white out of the rotation, and make them color-code BEAR notifications.

Friday, February 08, 2008

So that was a smooth application window. There was that one period for a couple of hours on Thursday where the USAC home page wasn't working, but I don't spend any time on the home page. Otherwise, I didn't even notice any performance loss.

Nice job!

Wednesday, February 06, 2008

Hidden meaning?

You know you've been spending too much time certifying 471s when you start seeing hidden meanings in the punctuation/word combinations of the PINs. Unfortunately, I can't give you any examples, since that agreement we accept the first time we use a PIN says that if anyone else learns our PIN, we have to eat the little secure mailer that it came in. Or something like that.

I suppose I could change them all, and then talk about the originals. Maybe that's what I'll do the day after tomorrow when I can once again think about something other than the looming deadline.

Tuesday, February 05, 2008

And another thing

Here's another "feature" of the 471 that gets my goat. You can't put anything in Item 23f, Annual non-recurring (one-time) charges, for Basic Maintenance FRNs. Meanwhile, in the real world, many manufacturers' service contracts have one annual payment. So now I've got to divide by 12, and my clients always seem to lose four cents on the deal.

Memo to USAC: don't assume recurring services require recurring payments. Even better, don't try to make synonyms out of "monthly" and "recurring," or "annual" and "one-time."

And I've already pointed out the dissonance with the online Item 21 Attachment.

Tab this!

Pardon me while I vent.

I keep seeing the application filing tips that were originally in an October News Brief, and there's one that sticks in my craw:

"Use the Tab key to move sequentially through your forms."

It bugs me because throughout the USAC Web site, the tab order is messed up. Next time you're certifying a 470 online, try tabbing after typing in the PIN. You jump to someplace up in the address bar, and it's like 10 tabs before you get back down to the next check box on the form.

Or try the certification page on the Form 471. Hit the Tab key after checking Item 37, and you don't go to the next item (which is Item 40, but that's a different rant), you go to the Print Preview button.

Hitting the Tab key is like spinning a roulette wheel.

Someone should be forced to use the USAC Web site without a mouse and write down all the unexpected results. They would wuickly run into a related pet peeve. On a normal Web form, after you type in some information and hit the Enter key, it's like clicking the Submit button. Not so on a USAC form. Some random button is pushed. Try displaying a 471: you type in the 471 number and hit the Enter key, it sends you back to the application menu page.

And don't get me started on why my browser's Back button doesn't work in some of the applications.

On the plus side, it's my impression that the Tab and Enter keys work more or less as expected on the new forms. So maybe the problems are already being fixed. Slowly.