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Wednesday, May 09, 2012

WANtankerous

At the end of last week, we got a few new orders, but only one of them merits some comment.  This appeal involves a school district that leased a WAN back in 2006, and USAC denied them because they said upfront charges could not be paid because it wasn't a telecommunications service.  The FCC said it was a telecom services, so the upfront charges were OK. First, my compliments to the FCC, followed by a snarky comment on a footnote.

Unlike many recent orders, which give no guidance, this order actually clarifies the eligibility of WANS a bit.  Mostly it's just a restatement of earlier precedent, but it does flesh out the FCC's current thinking on WANs a little.

And now for the snark:  Footnote 11 says, "See Billings FCC Form 471, Item 21 Attachment, Funding Request Number 1448250."  Why do I have an issue with that?  Because we can't see that Item 21 Attachment.  Or any other Item 21 Attachment.  Those attachments are not made public, and given that the FCC considers material collected during PIA reviews to be secret, I don't know whether you could even get them with a FOIA request.

Free the Item 21 Attachments!

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