Set the I2As Free!

My last blog post has inspired a rant.  (I can hear long-time readers muttering, "What doesn't inspire a rant in this guy?")

I mentioned that the estimates of the cost of President Obama's E-Rate initiative are not entirely based on hard numbers.  Why?  Because no one can say what schools are paying for a 100 Mbps connection to the Internet.  I have those numbers for my clients, but after talking to colleagues about prices in urban TX and rural OK, I know that my clients aren't getting the best prices, but they are far from the worst.

Why don't we have prices?  There is one main reason, which USAC could fix today, and one lesser reason, which would take FCC action to fix.  [Apology to grammar police: since that sentence included two reasons, I suppose it should have started with "There are...," but "There are one main reason..." sounded too weird.]

The main reason: information from the Item 21 Attachments (I2As) is not public.  The information from the Form 471 is public, so I can tell you how much schools are spending on telecommunications, and who they're paying, but I can't tell you what they're getting for their money.  To see Item 21 Attachments, I'm supposed to supply the 471 number and the security code, which is known only to the person who created the 471.  Even service providers can't see the Item 21 Attachments posted by their clients.

The lesser reason: the Item 21 Attachments (I2As) are not well standardized.  The attachments filed online are pretty consistent (much better than, for instance, the Form 470).  Those filed on paper are less standard.  The FCC really needs to tighten up the format for the I2As, so that the right information is corrected in the right format.  And convince everyone to file online.  How?

• The carrot: Create a "Same as last year" button that would allow applicants to autofill their I2As based on the previous year, then edit as necessary.
• An even sweeter carrot: Allow applicants to upload I2A data in a spreadsheet.  And download, too.
• The stick: Establish Minimum Processing Standards for I2As, then wait until after the window to data-enter I2As, so that paper filers who make a mistake are stuck out of window, and lose funding.

A lot of work just to allow a few E-Rate geeks to mine the data to improve our estimates on the cost of Obam-E-Rate?  Making I2As would have other positive effects.  For example, when an FCC decision says, "See Item 21 Attachment," we would actually be able to see it.  An informed public is a good thing.

Publishing the I2As would also increase competition.  Keeping the information secret prevents the free flow of pricing information that is crucial to a competitive marketplace.  If I had to guess why I2As are secret, I'd bet that service providers are fighting against it, because the improved competition would mean lower profit margins.  And the poor Baby Bells still can't kick the monopoly sentiment that competition is simply too plebian.

But here's the math that's really scaring service providers: I2A + LCP.  Ever since some lawsuits and a news article forced USAC to drag Lowest Corresponding Price (LCP) out of the dank cell where it had languished since the start of the program, applicants have been saying, "Well Lowest Corresponding Price sounds great, but how are we supposed to determine if we're getting LCP?"  Well here's the answer: public I2As would allow applicants to determine the Lowest Corresponding Price, At Least Among E-Rate Applicants (LCPALAE-RA).  I2As would put some teeth into LCP.  Not a full set of teeth, but if you've ever watched what a baby can do with just two incisors, you know that a full set of teeth is not required.

The free flow of information.  Increased competition.  Lower prices.  Compliance with the Telecom Act.  For all these reasons, Free the I2As.  Oh, and standardize them, too.