Extry! Extry!

USAC has released a Special Edition News Brief that the FCC has set the denial thresholds for 2011 and 2012.
For 2011, applicants at 88% and higher will get funded.
For 2012, applicants at 90% and higher will get funded.
That was fast: the USAC board just approved on Monday requesting those levels from the FCC.

OK, first it's laughable that the FY 2011 denial threshold got set one month after the end of the funding year. The whole idea of funding year has become largely meaningless for Internal Connections projects.  I can't remember the last time a client spent Internal Connections funding inside the funding year for which it was approved.  And applicants at 88% will be getting maintenance funding approved too late to actually spend it.

But the denial threshold for 2012 is almost timely.  It should be set before the start of the funding year, but at least it's close.  At least we all know the threshold for this year before we go into the next application cycle.

Once upon a time, I had a dream of the FCC announcing the denial threshold before the start of the filing window.  Now the FCC could actually do it.  Because I can tell you right now: no one below 90% is going to get a red cent for P2 in 2013-2014.  The FCC can't guarantee that 90% applicants will get funded, but we can all be damned sure that no one below 90% will get anything.

So here's what I'd like to see.  The FCC releases this week The Pro-Rating Order and Notice of Proposed Rulemaking.

The "pro-rating" part would say: "If your discount is below 90%, kiss P2 funding good-bye.  If, as expected, the cap plus rollover funds available as of June 15, 2013 are not sufficient to cover the demand for Priority One services plus demand for Priority Two services from 90% applicants, we will allocate funding based on a pro-rated basis."  That would be so painful that all the proposals in the NPRM would look good in comparison.

The NPRM part would say: "We will never again have enough funding to cover P2 funding for even 90% applicants, so we need to do something.  Here's what we're thinking:

1. Cut the top discount level to 75%
2. Toss some services out of the program.
1. Maintenance is just a headache and a great place to run small scams.  No one understands the rules.  Approvals always come too late.  Wash it all down the drain.
2. Web hosting costs are out of hand.  If the going market rate for unlimited disk space and unlimited bandwidth is less than $100/year, how do the value-added Web hosts keep a straight face when they say 95% of their $10,000/year cost is for Web hosting?  So we'll discount the first $100/year, that's it.  Wait, what are we saying?  $100?  Forget it; hold a bake sale to cover your Web hosting costs.
3. Now that blade servers and virtual machines are all the rage, the eligibility of servers is a moving target and beyond the ability of the human mind to calculate.  Pay for your own damned servers.
4. You can only have funding for cell phones and mobile Internet if you certify that you'll collect all those devices from employees when they leave the building.  Sorry, allowing your Superintendent to check her Facebook page on her ride home is not the purpose of this program.
5. POTS lines are so last century.  This program is supposed to be about "advanced technology." Get yourself some VoIP.  Can't get anything but POTS in your area?  Go complain to the High Cost Fund.
6. Toss Data Protection and be done with it.  We were never sure about firewalls and proxy servers, and anti-virus and anti-spam were never eligible, so why are we paying for uninterruptable power supplies?  And ask an engineer about the advantage of tape backups over a hard disk backup: it's archiving, not backup.  VPNs?  Get real; people are using them for network access from ineligible locations.  Toss the whole category.
7. Get rid of paging services.  No one but custodians has used a pager in 10 years.  OK, so it won't reduce funding demand by much, but it will save some space on the ESL.
8. Look, the only thing eligible under "video" is video distribution, right?  Well, everyone transporting video over their data network, so let's kick video out of the program.
3. Make an adjustment to the cap to compensate for all those years the fund wasn't indexed to inflation.
4. Let's replace the "2-in-5 Rule" with the "Dinner Table Rule": don't take seconds until everyone has had firsts.  So if you get P2 funding this year, go to the back of the line and wait until everyone else has had some.  No, it doesn't solve the funding problem, but it disperses the crumbs more widely.

OK, the Dinner Table Rule is a bad idea.  But all the rest of the ideas are better than pro-rating.