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Monday, March 31, 2008

No more timeouts

Every now and then, I have something nice to say about USAC's online tools. Today, I come to praise the online Item 21 Attachment.

First, of course, the rant: Why can't I just import last year's attachments? Most of the time, services are similar, so for each FRN, I'd like to opportunity to put in an FRN from the previous year and have all the info pop in. I've just about reached the point where I'm going back to paper, because that way I can just edit last year's and submit it. Also, how about asking for all the info on one page, instead of making me click, click, click to get through the process? And finally, when I click on the link to bring in the amounts from the 471, why does it erase any information I've already put in that page?

Now for the praise: I think the timeout is completely gone. I just ate dinner in the middle of doing some Item 21s, and when I returned, I was able to resume where I left off without any pesky timeout kicking me out. I like it!

Tuesday, March 25, 2008

Well, isn't that ESPAcial!

Kudos to the E-Rate Service Providers' Association (ESPA) for their comments to the FCC on eligibility. When announcing the last ESL, the FCC said, "this proceeding is limited to determining what services are eligible under the Commission’s current rules and is not intended to be a vehicle for changing any eligibility rules," and suggested, "those comments not addressed in the Funding Year 2008 ESL may be more appropriately filed for the Commission’s consideration in the general proceeding for the Schools and Libraries Universal Service Support Mechanism in CC Docket No. 02-6." Until now, no one had bothered to take them up on that.

Now ESPA has resubmitted its comments along with a cover letter suggesting that the FCC allow the public to submit suggestions for changes to eligibility, instead of the current policy, which is that only clarifications are allowed. Unfortunately, that would throw off the current FCC timetable, which is to get the draft ESL from USAC in March, sit on it for 5 months, release it (unmodified) in August, allow one week for comments, then make an edit or two over the next 2 months, release it in November, and waive its own rule, reducing the time between the release of the ESL from the 60 days (as set in the Third Report and Order) to a week or so.

Resubmitting my ESL suggestions has been on my to-do list for months now, but I don't know if it will ever get to the top of the list. The ESPA submission is a motivator, though.

Monday, March 24, 2008

Gateway gets me halfway

A recent letter made me happy, then I got cranky. Following the FCC's instructions from the Alaska Gateway Order, USAC sent me a letter warning me that a 486 might be overdue.

First, the happy: This is the way the program should work: make a mistake and miss a deadline, and you get a second chance. I don't have trouble keeping track of deadlines, since it's all I do, and I have automated systems to keep me on top of things, but applicants who are doing it themselves just can't keep track of all the deadlines. The 486 deadline was very frequently missed, because it isn't the same date every year, and it's a pointless form anyway. So it's nice that fewer applicants will lose funding because of it.

Now, the cranky: This particular reminder came for a 486 that is required because of an operational SPIN change/FRN split. That is, a funding request where the applicant switched service providers in the middle of the year, so the funding needs to be split between two service providers. Because USAC's database only allows one service provider for each FRN, a new FRN has to be created. And then USAC requires a new 486 for the new FRN. Why? It's not a new funding request. "FRN" is not a synonym for "funding request." An FRN is a database record used to record a funding request. An operational SPIN change does not create a new funding request. So a new 486 should not be required. All the certifications were already given with the 486 for original FRN. The service start date was given in the SPIN change. The 486 is just a waste of everyone's time in cases like this. The new FRN should be covered by the 486 filed for the original FRN.

Monday, March 03, 2008

2-in-5 is 0-4

The "Two-in-Five Rule" fails again. It has failed every year. Man, I hate the 2-in-5 Rule. I've stated my reasons before. This rule has got to go.

USAC just released its demand estimates for 2008-2009. Overall demand is up 16%, Priority 1 demand up 9%, Priority 2 demand up 24%, blah blah blah. But here's the number that jumped out at me: Priority 2 demand by 90% applicants is up 50%. That's exactly the demand that the 2-in-5 rule was supposed to suppress. What a spectacular failure!

With the Priority 1 at $1.95 billion, Priority 2 for 90% applicants at $1.07 million, we're over $3 billion in requests right there. E-Rate Central listed recent approval rates, and showed that for 2007-2008, about 86% of requests are being approved. Assuming that the approval rate for 2008-2009 is 86% (which ignores the upward trend in recent years, but let's be conservative), USAC will need $2.6 billion just to fund the 90% Priority 2 requests. So the FCC had better let this year's denial threshold stand at 83% and start stockpiling cash for next year.

In fact, the FCC had better roll over the $450 million now available into 2008-2009 right now. Otherwise, USAC will not have enough cash to fund any Priority 2 requests for 2008-2009, since it won't have enough income to cover all 90% applicants.

The Priority 2 funding system is broken, and the 2-in-5 Rule just makes it worse.