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Tuesday, January 31, 2012

Digital Literacy Corps moving in next door

The monthly Washington Update from the Consortium for School Networking (CoSN) informs us that the FCC Chairman has decided not to use the E-Rate to fund the Digital Literacy Corps.  Back in October, the Chairman seemed to be planning to fund it from the E-Rate, but the pushback from E-Rate stakeholders has apparently made him rethink that.

Good news for the E-Rate, which is already short on funds (and getting shorter).  And Lifeline is the catchy name for the Universal Service Fund Low Income Program, which is not capped, so the change will not be taking funding away from anyone.

Of course, I have to look for the downside.  I don't imagine this Digital Literacy Corps will cost much, but whatever the cost is, it will increase the size of the USF, which means increasing the contribution from service providers, which means higher prices on everyone's bills, which means more political opposition to the USF.  Not a big concern, but I've been worrying since Obama took office that mission creep in the USF will put the squeeze on the E-Rate.  Now it seems that a direct squeeze on the E-Rate was avoided only because of advocacy by organizations like CoSN, and we're still looking at an indirect squeeze.

And as I've said before the Digital Literacy Corps is not really necessary.  Libraries are already running digital literacy classes, as are many school districts.  But if they want to give the existing effort a catchy name, I'm OK with that.  Let's not spend too much money on it, though, OK?

Monday, January 30, 2012

Throw Competition out of the Window

It's official: the FCC does not want E-Rate applicants to lower their telecommunications costs.  Well, at least USAC believes that's so.

In the latest News Brief, USAC talks about the heinous new rules for changing service providers (called an "Operational SPIN change").  Mostly, it just restates the bad news from the Sixth Report and Order: 1) you can only change service providers for a legitimate reason, and 2) you have to switch to the second-place finisher in the bidding from the original 470.

But then comes a new clarification of the rule: "Changing service providers because the services are available at a lower cost from another provider ... [is] not considered [a] legitimate reason for change...."  Crap.

This means that applicants are locked into prices for no good reason.  Let's take this example: I post a 470 which includes local and long distance for 20 POTS lines, get no bids (not unusual), stick with my existing service provider and file a Form 471 in March.  In April, along comes a new service provider with lower prices.  Sorry, I can't take advantage of the lower prices until the following July, 15 months later. What a waste of local tax money and E-Rate funding.

The problem is the filing window.  The FCC wants to maintain the fiction that the Form 470 process increases fair and open competition.  I don't agree, but fine, let them have their fig leaf.  But there is a solution that gives applicants the flexibility to switch to a more cost-effective service at any time, while preserving the 470 sacred cow.  The crux of the solution is that the procurement process should be decoupled from the filing window.  Three changes are required:

  1. Unhinge the 470 from Funding Years.  I already suggested here this should be done, and SECA made it part of a formal filing with the FCC.
  2. Allow applicants to choose a new service provider at any time, as long as they post a Form 470 for 28 days.
  3. Do not require that contracts used to justify pre-discount amounts on the Form 471 cover the entire funding year.  Actually, don't require that the contracts cover any part of the funding year. Actually, don't require any contract.
I had you until that last one, right?  I know it seems whacked, but hear me out.  Why do contracts need to be signed in the window?  It's not like you're getting any actual funding when you file a Form 471.  (As SECA has noted, you're not even getting a real commitment.) You're just setting a cap on the funding you'll receive later when SPIs or BEARs are filed.  So while applicants should have some justification for how they arrived at the pre-discount amount on the Form 471, let's allow them to use the cost of existing service, an existing contract or a quote for new service.

The Form 471 as a Description of Services Ordered only made sense before the invention of the filing window.  Now it makes no sense to require fictitious contracts months before the start of service.  (The contracts are fictitious because actual contracts would be illegal.)  The name of the form should be changed to Description of Services to be Ordered Later When We Have an Approved Budget and We're Ready to Start Using the Services.

If I were king, every year applicants would file a Form 471 in March (actually, King Dan would make it May) with estimates on spending, and after application review, funding caps are set.  Then whenever applicants want, they post a Form 470, collect bids for 28 days, then select a service provider.  Move the "I ran a fair and open competition to select this service provider" certification to the BEAR (or the Form 486, if you must).  I guess, actually, it makes sense to move SPIN selection to the 486, so that USAC doesn't make itself crazy with SPIN changes.

If you end up with a higher price after posting a 470, tough luck.  But I don't think that would happen often, given the direction of telecommunications and network equipment trends.

Free the competition!

Thursday, January 26, 2012

Common Sense comes to the E-Rate

I just learned of a resource that I thought I'd pass along.

As all you school folk should know by now, the FCC has implemented a change to CIPA requirements effective July 1, 2012.  By that time, schools need to update their Internet safety policies to “provide for the
education of minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response."

Shortly after the law was passed in 2008, a couple of vendors started offering canned curricula to meet this requirement, and have sent out unsavory marketing emails with dire and misleading warnings about loss of E-Rate funding, and offering to provide a "appropriate online behavior curriculum" for a price.

Now it is actually time for dire warnings: comply with the new requirement by July 1 or lose funding.  And today, I learned of a free resource for curriculum from Common Sense Media.  I think you have to register (giving your name, email address and school) to get the content, but it's free and looks comprehensive.

(By the way, for you parents out there, Common Sense Media also offers pretty good movie reviews when you're wondering if the latest movie releases are appropriate for Junior.)

Thursday, January 19, 2012

E-Rate milestone

How did this escape my notice?  A better question: why wasn't this the subject of a News Brief?

Ever looked at a 470 number?  At first glance it just looks like a painfully long string of numbers that you have to enter in FRN after FRN when you're filling the 471.  But those of us who have looked at thousands of them see a pattern: a 5-digit random number (hey, just like the PIN for a 471), then 4 zeroes, then a 6-digit number.  And that 6-digit number is sequential, just like the 471.

But no more!  On January 16th, the Archbishop Borders Elementary School clicked Submit on Form 470 #185380001000000. That's right, the millionth 470 has been filed!  Cue the confetti!

Well, it's only the millionth 470 created, not submitted, but don't rain on my confetti.

So usually the millionth customer gets some kind of prize.  What would be an appropriate prize?

Friday, January 13, 2012

Nearing compliance

Three appeal decisions hit the streets today.  One is a single appeal, but the other two are big piles of waivers, one for late 471 filings, one for late 486 filings.  Two things struck me:

  1. The FCC made no attempt to explain why the appeals were granted or denied.  The basically just said, "Here's what we're waiving, here's what we're denying."  Which makes it look like some waivers have become truly routine, which is good.  On the down side, it provides no precedent for later appellants, but there is enough precedent out there for this kind of waiver.
  2. Of the 53 appeals decided, the oldest was from June, a mere 7 months ago.  Most of the appeals were from October or later. If they're not careful, the FCC is going to start complying with the requirement that all appeals be decided within 90 days (see 47 C.F.R. 54.724)
So I hope that the WCB has a wonderful weekend, because they've earned it.

Friday, January 06, 2012

Over-extended

Today's interesting factoids from our database guy:
Currently, there are roughly 16,800 FRNs extended for 2010-2011.  Out of a total of 134,000 FRNs total in 2010-2011, of which 118,000 are funded.  So over 14% of funded FRNs are extended at the moment.

Does that seem like a system that's working?