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Saturday, April 16, 2011

A Tale of Two Errors

It was the best of orders, it was the worst of orders.

Let's start with the name. The best of names: the "E-Rate Correction Deadline Order." Excellent! The FCC's setting a deadline to correct this mess. Wait a minute, it's spelled "Erate Correction." "Erate"?! Not capitalizing the "R" is wrong, but dropping the hyphen is a sin.

The order itself starts out the best of orders: USAC is instructed to allow corrections until the FCDL is issued, even it that's longer than 15 days. Bishop Perry Everlasting! Excellent!

Or is it the worst of orders? The FCC makes it clear that the extended response time is only for "truly ministerial and clerical errors." Uh oh. "Such errors include only the kinds of errors that a typist might make when entering data from one list to another, such as mistyping a number, using the wrong name or phone number, failing to enter an item from the source list onto the application, or making an arithmetic error." Did Bishop Perry just get gutted? Up to this point, USAC has been letting applicants correct errors without paying too much attention to the meaning of "ministerial." I'm afraid that this order is going to make them pay attention to whether the error is "truly" clerical.

But at least the FCC now has extended time to correct the spelling of "E-Rate" in the name of this order.

Friday, April 15, 2011

2-in-5 is 0-7

Another year, another demand estimate.

First, the obligatory 2-in-5 Rule rant. For the 7th straight year, the 2-in-5 Rule has failed. Priority 1 requests plus the Priority 2 requests from 90% applicants come to 3.2 billion. (Could this be the year that the FCC can't find enough money to fund Priority 2 for 90% applicants?) Internal Connections requests from 80%-90% applicants are up 18% from last year. I'm tired of beating this dead horse, but I'll keep it up until they haul it off to the glue factory. The 2-in-5 Rule must go.

Speaking of horrible rules, look at the result of the new ineligibility of "unbundled warranties": a 20% jump in Basic Maintenance requests by 90% applicants. Not to worry: many applicants still have no idea that their SMARTnet and PBX service contracts are no longer eligible, and they won't know how to cost-allocate when PIA smacks them, so look for denials to skyrocket.

Other observations:
Internet access requests are up about 17%, while telecom requests are only up about 3%. I'm guessing it's dark fiber and the loosening of Web hosting rules.

After a 77% drop last year, this year we see a further 65% drop in Internal Connections requests from applicants with a discount of less than 60%. The message is finally getting through: if your discount is less than 80%, the Priority 2 gravy train does not stop at your station, so there is no point in waiting on the platform.

Wednesday, April 06, 2011

For those of you tired of hearing me complain about the spelling of "E-Rate," you'd better skip today's gripe.

Has anyone else noticed that PIA reviewers are spelling it "ERate"? I think the Subject line of every PIA request I've received so far this year includes "ERate." While I applaud the capitalization of the "R," the lack of hyphen is a greater sin than a small "r."