Search This Blog

Wednesday, October 29, 2014

Obfuscated Eligibility List

The final Eligible Services List for Funding Year 2015-2016 is out.  Since it's basically like the draft ESL, most of my comments on the draft apply to the final (except they added MPLS and made WAP antennas eligible).  Still, I can't let some of the things in the order pass uncriticized.

To address "uncertainty among some applicants regarding services that are no longer eligible for E-rate support..., we include as Appendix B to this order a chart identifying the equipment and services that were eligible for E-rate support in funding year 2014, but are no longer eligible as of funding year 2015."  So that 1% of applicants who actually read FCC orders will be aware of these changes.  The other 99% who rely on the ESL will just have to be alert.

"The ESL is not intended to serve as the central collection for all E-rate program rules and policies. Even the current ESL is not dispositive of all of the precedent related to E-rate program eligibility. It would be inappropriate to leave applicants and service providers with the impression that the ESL is a comprehensive source of all information pertaining to E-rate eligibility. As we have emphasized, applicants and service providers are required to know the relevant rules of the E-rate program and are ultimately responsible for compliance with them."
What I'm hearing is:
"It would be too much work for us to search out all the eligibility rules in this program and put them in one document, so we're requiring each of the 20,000 applicants to search out all of those rules.  And we hope that by making the ESL so obviously inadequate, it will be clearer to applicants that they have a lot more searching to do."

What is the correct spelling for the sound of teeth grinding?

"there may be other high-speed broadband services that fall within the rubric of eligible digital transmission and Internet access services."  First of all, no need to say "may be";  there "are" other digital transmission services.  Second of all, what happened to the "if it's not on the list, it's not eligible" principle?  Now they seem to be saying, "if it's not on the list, it 'may be' eligible."  At least they put MPLS on the list.

Hey, they defined caching!  That's good news.  I'll be interested to see how many ISPs start offering a caching service which uses On-Premise Priority Category One Equipment.

My concern about antennas has been addressed.  That's a relief.

So my quixotic crusades against cell phones, voice service in general and video have succeeded (and 2-in-5 is also gone, kind of, maybe temporarily).  So I think I'll focus my wrath on On-Premise Priority Category One Equipment.  In addition to being a crock, if has proven over and over to be a loophole too tempting for service providers to resist (remember the Sprint case?).  And with the new C2 budgets, even the 90% applicants will have an incentive to push their equipment into C1.  Let's get it out of the program.

No comments:

Post a Comment