E-rate by any other name

I just can't give up on capitalizing the "R" in "E-Rate." As faithful readers know, after chastizing others for their spelling of our beloved program, I recently noticed that my spelling is not the same as the FCC's.

So of course I'm thinking that the FCC is wrong, and I set out to prove it. So I thought I'd start with the Telecommunications Act, which created the E-Rate (OK, E-rate, whatever). Alas, "E-rate" does not appear in the law. So I went to the regs: again, bupkus.

Well, what about the founders of the E-Rate? Well, it was called the "Gore Tax," so I thought I'd see how the inventor of the Internet spelled it. Alas, I could not find any writings from Gore using the term "E-Rate."

The E-Rate was the result of the Rockefeller-Snowe-Exon-Kerrey Amendment, so let's see how those senators spell it. The first 10 documents that Google listed from Rockefeller's Web site with "E-Rate" in them included 7 using "E-Rate" and 3 using "E-rate." Damn, Senator, make up your mind. The "E-rate" documents were all 2001 or earlier, but there were some early "E-Rate" spellings, too.

On to Senator Snowe. Google found only 3 documents on her Web site (understandable that a Republican does not want to trumpet her involvement with this program). All "E-Rate." Way to go, Sen. Snowe!

Senator Exon? Never heard of him. (How much did the Exxon lobbyists have to pay him to change his last name? And why didn't they pay him a little more to add the second x?) I can't find anything written by him with "E-Rate" in it.

Senator Kerrey. I only found two documents. One used "E-rate," the other "e-rate." Booooo!

Well, at least I'm not the only one who's been spelling it "E-Rate," but I can't say that the will of Congress was to have that "R" capitalized.

Maybe if I file an appeal with the FCC, asking them to capitalize the R? They seem willing to grant just about any appeal these days. Nah, they'd probably just grant me a waiver with that "narrow focus" paragraph at the end, and USAC would interpret it to mean that any documents that capitalize the R should be denied.

Did I say that out loud?