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Tuesday, March 22, 2016

A Modest Proposal

After a conference call today listening to normally circumspect people throwing rocks through the filing window, it occurred to me that instead of extending the filing window, we should reset it.  Instead of acting like it's just a little extra hassle this year, USAC and the FCC should acknowledge that the current status of the forms is unacceptable, and close down the window, reopening when the forms are ready.

Does that seem extreme?  Well, consider a statewide consortium.  The number of entities on their Form 470 is autofilled by the system, based on the data in each of the billed entities in the consortium.  So until every entity has created an Account Administrator and corrected the hash of related entities (which did not import into the new system correctly for a large number of applicants), checked parent/child relationships, converted BENs to annexes as necessary, etc., etc., the consortium can't file a correct 470.

And there are elements of the system that worked last week, but don't work this week.

It's just not fair to ask applicants to use a filing system that isn't even stable, much less complete.

So let's open the window when the forms are complete and stable.

We wouldn't need as long a window, since applicants will have prepared once already.  But the FCC has hinted that they want 60-day bid periods for complex fiber builds, and we should allow those applicants to have 2 weeks to review proposals, so we need a 75-day window.

So there's my suggestion: finalize the application system, then open the window for 75 days.  I'm guessing we're a month or two away from a stable, complete application system, so we probably wouldn't be able to close the window before the start of the funding year, but that doesn't seem as bad to me as asking applicants to use a broken system.