NPRM in the oven

Well, the FCC has approved the NPRM 3-0.  Now when will we see it?

I tried to take notes, but mostly I just jotted down things that struck me as interesting.

One thing I hadn't noticed before: the ConnectED initiative goal is to get high-bandwidth connections to 99% of students, not 99% of schools. That's bad news for small schools.  Why would the E-Rate pay $10,000/month to get broadband to some remote school with 20 kids when they can pay $1,000 to get broadband to a suburban school with 500 kids?

Some of the changes I heard:

1. Shifting funding priorities.  It seems like maybe we'll see Priority One become bandwidth and WLANs, and everything else is P2.
2. Update the ESL.  Translation: dump voice services.
3. Identify more efficient architectures.  Could this be an attempt to get cell phone data plans out?
4. More equitable distribution of funding.  The 90% gravy train is going back to the roundhouse.
5. Driving down prices.  More about this later.
6. Changes in CIPA applicability.  Interesting, but probably nibbling around the edge.
7. Get better data.  This means bigger forms, like the new Form 471, which is going to include a "Block 2 From Hell" for each FRN.  (By the way, notice that the 471 will no longer collect data on voice service.  Is that "Taps.." I hear playing in the background?)

About driving down prices, I heard four suggestions:

1. Increasing use of consortia:  Nope.  Consortia increase complexity, and only lower prices sometimes.  Sometimes they increase prices.  And they are always more difficult to get funded through E-Rate.
2. Bulk purchasing: Well, it's a nice idea, but it's totally hamstrung by the Form 470 process, since you have to identify who is covered by the 470 before filing, so new members can't take advantage of the pricing. And combining state contracts with the E-Rate is a headache.
3. Transparency:  Yes! The level of secrecy in this program is astonishing.  For some reason, Item 21 Attachments are secret, so none of us can see what other people are paying for services.
4. Improving procurement process:  There is only one thing the FCC needs to do to improve procurement: stop trying to regulate the purchasing decisions of locally elected school boards.

We didn't hear a peep about the most effective option for driving down prices: Lowest Corresponding Price. Maybe it's in the full NPRM.  Or maybe the telcos spiked it.

And now the wait begins.  Since the Commission gave the WCB the right to edit the NPRM, does that mean there will still be some changes before we see it?  That could be weeks.