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Monday, August 04, 2014

Hidden dragon?

Hmm ... what are the "Other Rules Changes" in paragraph 182 of the 7R&O?  Oh, it's only one change, adding a definition for "consortium," and the FCC says, "This change does not alter requirements for applicants and service providers."  On to the next paragraph, right?

Let's take a look at the definition.  It's at the top of page 123.  It says, "Eligible schools and libraries may not join consortia with ineligible private sector members unless the pre-discount prices of any services that such consortium receives are generally tariffed rates."  Say what?

Right away I'm thinking about a consortium I worked with that included some non-profits, which was a pain in the allocation, because I had to calculate what proportion of services they were using and remove it from the 471 FRN and the BEAR.  That consortium is apparently no longer eligible for E-Rate funding.  Then I thought how many large networks include private universities.  I did some checking on a few statewide networks.  I seems the Alabama Supercomputer Authority, the Utah Education Network and CENIC all include private colleges and universities.  So I guess those consortia are no longer eligible for E-Rate funding.  Then I got thinking about all those Catholic dioceses that include a college or university.

Well, that doesn't seem to be encouraging consortium purchasing.


  1. I guess this is related to the weird rule hidden in the Form 471:

    It seems that the FCC is very concerned that the E-Rate program not lower costs for ineligible non-governmental entities. I wonder why.

  2. OK, after perusing 47 C.F.R. a bit further, I see that this is just copying info already in 47 C.F.R. 54.501(c)(1) into 47 C.F.R. 500(d). Consortia with private entities have always been forbidden. Except Washington state, which got a waiver: