A wave on the horizon

When will the first FCDL go out?  Yesterday the FCC approved the Schools and Libraries Funding Year 2014 Program Integrity Assurance FCC Form 471 Review Procedures.  That means PIA can press the "Approved" button any time.  Is this the first time the procedures have been approved inside the filing window?  Let me take a quick look back:

Window close	Days passed	PIA approved	Days passed	First FCDL	Total days
3/26/2014	-19	3/7/2014
3/14/2013	57	5/10/2013	19	5/29/2013	76
3/20/2012	35	4/24/2012	77	7/10/2012	112
3/24/2011	75	6/7/2011	19	6/26/2011	94
2/11/2010	91	5/13/2010	13	5/26/2010	104
2/12/2009	49	4/2/2009	26	4/28/2009	75
2/7/2008	63	4/10/2008	21	5/1/2008	84

(I stopped at 2008 because I couldn't quickly find earlier procedure approvals.  Maybe the FCC didn't approve procedures before that?  Or maybe the approvals were as secret as the procedures?)
It is the first time the procedures have been filed inside the window.  The FCC has never before come within a month of the close of the window.

So now that the PIA procedures are approved, there is theoretically no reason that we couldn't see some FCDLs on Tuesday.  But that seems unlikely; while some applications have gone into PIA review, there doesn't seem to have been enough PIA activity to create a wave.

When will we see the first wave?  The optimist in me says March 25th.  Because it would look nice to have the first approval take place inside the window, and historically, USAC has been able to turn around the first wave in 19 days from PIA procedures approval.  My inner pessimist says May 20th, because the first wave has only come earlier than May one time.

Normally, I'd say that USAC would have to wait until they release the Demand Estimate, so that they can be sure they have enough funding to meet Priority One demand.  The Demand Estimate seems to come out about 40 days after the close of the window.  But this year, the recent NPRM said that the Commission has found an extra $2 billion, and in a recent speech, Chairman Wheeler committed to funding Priority One for FY 2014-2015.  So maybe USAC doesn't have to wait for the Demand Estimate.

Still, betting on some time in May seems sensible.