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Thursday, November 20, 2014

Where's that window?

So now that we know that the new Form 470 will go live tomorrow, the next question is, when will the new Form 471 go live?  On the first day of the filing window, I suppose.  When will that be?  The ESL is out, so USAC can pick a date whenever they like.

Which got me wondering: what is normally the delay between ESL release and announcement of the filing window?  The answer:
FY ESL release Window announced Days to announce Window open  60 days? Window close Window days
2005 10/14/2004 11/5/2004 22 12/14/2004 61 2/17/2005 65
2006 11/22/2005 11/23/2005 1 12/6/2005 14 2/16/2006 72
2007 10/19/2006 10/20/2006 1 11/14/2006 26 2/7/2007 85
2008 10/19/2007 10/28/2007 9 11/7/2007 19 2/7/2008 92
2009 11/21/2008 11/24/2008 3 12/2/2008 11 2/12/2009 72
2010 12/2/2009 12/3/2009 1 12/3/2009 1 2/11/2010 70
2011 12/6/2010 12/10/2010 4 1/11/2011 36 3/24/2011 72
2012 9/28/2011 11/22/2011 55 1/9/2012 103 3/20/2012 71
2013 9/27/2012 11/13/2012 47 12/12/2012 76 3/14/2013 92
2014 10/22/2013 11/20/2013 29 1/9/2014 79 3/26/2014 77
2015 10/28/2014 11/20/2014 23 12/27/2014 60

[I started with 2005 because that's when the Third Report and Order created the requirement that the ESL be released at least 60 days before the start of the filing window.]

The information in green italics is "what-if" data.  If USAC announced the window dates today, that would be 23 days after the ESL was released.  If the window opened exactly 60 days after the ESL release, that would be December 27th.

This year is different, because USAC has to deal with a major systems overhaul before opening the window.  The Form 470 changes were very minor, but the Form 471 is a whole new beast.

So my uneducated guess on the window dates is:
Window opens: January 15
Window closes: March 25

That would give us a 69-day window, which is the shortest since 2005, but not a lot shorter than recent years.

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