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Tuesday, December 06, 2016

Campus? More like Krampus.

Back when I live-blogged training, I pointed out the muddled misery caused by campus vs. location vs. school vs. entity.  Now the latest News Brief brings some additional information, which, as usual, means additional pain and confusion for applicants.

First, the definition of "campus" just got even muddier.  It used to be the only thing that split a campus was a public right-of-way.  Now any road (not necessarily public) or stream can split a campus.  What?!  Now I have to walk my clients' campuses looking for streams to see if I need to create annexes because there are different campuses?  Do gulches that only have water sometimes count as streams?  We can assume that if streams split campuses, rivers certainly would, but what about brooks or rills?  What if a stream runs between two buildings, but only partially crosses the campus?  What if a road crosses a stream? Can a stream/road combo create a separate campus?  Suddenly, I feel like I'm playing the latest expansion pack of Carcassonne.

Hey, our local primary school was built on wetlands (I know you can't believe it, but it's true).  Do wetlands count as part of a stream for purposes of determining campusity?

What is a "road" that's not a public right-of-way?  A driveway?  I can't find a good definition of "road" anywhere.  And the legal treatment of vehicular pathways seems to vary quite a bit from state to state.  How can I learn the legal status of the driveways on my campus to try to figure out if they meet the (non-existent) definition of "road"?

Now that I don't know whether I have one campus or several, let's use that non-definition to determine whether a service is C1 or C2.  Buckle up!

The first example looks easy: if you have one school on one campus, all connections are C2, even if you have multiple buildings on that campus.  OK, but what if Google Maps shows the vehicular pathways on my campus as roads?  Does that make them roads?  If the town maintenance department has to use that pathway to get to it's salt storage building, does that make it a road?  What if the driveway is shared by two schools?

How did they write the second example without mentioning the word "annex"?  That's what we're talking about, right?  What else would a separate location of a single school be called?  [Or will annexes go extinct when EPC hits the trash heap next year?  Oh, goody, we can make all those annexes back into entities (well, annexes are listed under "Related Entities," so I guess an annex is an entity, but you know, I mean "entity" as in "location with a Billed Entity Number," not "entity" as in "thingy in the EPC database, whether or not is has a BEN").]

And their example is ridiculous.  Choosing two campuses separated by a major thoroughfare was facile; how about using a campus with a stream through it as your example?  But then the unrealism kicks in: "The middle school has administratively defined the grounds on one side of the thoroughfare as 'Campus A' and the separate and distinct grounds on the other side as 'Campus B.'"  What?  "Administratively defined"?  What does that mean?  They call the two buildings by 2 different names?  Different mailing addresses? What if my lovely campus has a stream running between two buildings, but we've never identified them as separate campuses?  Are they still separate campuses?  When this hits the real world, no one will now what to do.

But the third example takes us from the muddy to the absurd.  Three schools in one building are 3 campuses, and connections between those schools are C1.  Oh, my aching head.  Let's just take an unrealistically simple example where each school has an MDF, and all horizontal runs stay inside school boundaries.  Now if I want to connect those 3 MDFs with fiber runs, those connections count as self-provisioned fiber.  Which means that I need to convince someone to give me a bid on a leased dark fiber and on some kind of lit fiber service inside my building, so that I can demonstrate that self-provisioned is more cost-effective than the other options.  What service provider is going to prepare that bid, knowing they can't beat the self-provisioned cost?  And what if the cable company does come in and proposes cable modems in every MDF VPNed together?  Dang, that's going to be pretty cheap.  Do I really have to put my LAN backbone on a VPN? I guess we have to put latency specs in our RFPs, which is beyond the expertise of your average school tech person.  So now the district has to hire a fiber engineer to do a design for a leased fiber infrastructure which is not going to be built under any circumstances.

And that's all in USAC's unrealistically clean example.  Let's take a pessimistic, but not unrealistic example.  Let's say you have a building that's basically just a 400-foot-long hallway with classrooms off each side (the hallway doesn't have to be straight; I can think of several schools that have U-shaped or O-shaped hallways that long).  It's a 3-story building, and you're going to put 3 schools in there, so naturally you put a school on each floor.  Because of that hallway length, you can't serve a whole floor with a single closet, but a clever network designer would realize that if you put in one closet on each side of the 2nd floor, each closet would be able to serve all 3 floors for half the building.  So what now?  Is each individual cable run to the first and third floors a C1 connection?  What does that make those runs, self-provisioned copper?  Is that eligible?  Do I still have to compare the cost of each run to a leased dark fiber and lit fiber connection between my classroom and the wiring closet?  Can I compare it to the cost of leased dark copper and lit copper?  (I know, no one offers that service, but no one offers lit fiber inside your own building, either.)   If I've got 4 runs to one classroom, do I have to get a bid for 4 leased pairs and a bid for 4 lit fiber connections?

And if all 3 schools share a cafeteria, and you put an access point in there, now I have to share the cost of that run and that switch port among the C2 budgets of all 3 schools.  And what if only 2 of the schools in that building share an art room?  As long as the drops in that classroom go back to a closet located in one of those 2 schools, I guess I just cost-allocate it between those 2 schools?

And then one of the schools closes, and a new school opens in that space.  (You would think that's very unusual, but some districts have figured out that if they create academies, when that academy fails to meet NCLB requirements for 3 years, they can just close that academy and open a new one, and they have a clean slate.  It looks like a district trying innovative new ideas, but it's just a shell game.)  Does the new school have to rebid the cable runs to its location?  What if that was the school on the second floor?  Do the other schools have to rebid their C1 connections to the second floor, since there's a new entity there?

OK, now I've gotten to extreme (but not unrealistic) cases. Most shared buildings will be somewhere in between.  Some closets will serve only one school, but most closets will serve classrooms in multiple schools.  So most closets will have both C1 and C2 connections.  Now the switches are going to have both C1 and C2 connections going into them, so you'll have to cost-allocate the cost of switches across categories?  There's a brand-new headache.

And then at some point the administration is going to decide to swap rooms between that ungraded special ed classroom (which has students from more than one school,so it's shared, so it's C2) and the 4th-grade classroom next door (which had been served by a closet in the Middle School sharing the building, so it was a C1 connection).  So the C2 connection becomes a C1 connection and vice versa.  Do I have to get leased dark fiber and lit fibers bids and compare them to the wire that's already there?  I can't even imagine what I'm supposed to do about a connection that was C1 and becomes C2.

And what about offices?  If the Superintendent's office is on that campus, what am I supposed to do about those connections?  Is an office that serves all schools in the building treated like a shared classroom?

You know what might simplify your life?  Find a shared room like the cafeteria, and put a fiber switch up on the wall.  Then have all your wiring closets connect to the cafeteria.  Since it's a shared room, all connections to it are C2.  And you'd have some great viral videos of the tech director with a lacrosse goalie stick trying to protect that switch during food fights.

Wait, who decides what is a "shared classroom"?  Can the schools just declare all wiring closets to be shared classrooms?  Then all the connections in the building are C2, regardless of which school they connect to.  Just don't look too closely, because the cost-allocation tangle could be extremely messy.

Excuse me, I need to find some aspirin, since it's too early to start drinking.


  1. An observant colleague pointed out what the ESL says about campuses:
    Q6. What about a single school campus that is intersected by a public right-of-way, with instructional buildings located on either side of the public right-of-way? Would the connections between all of the instructional buildings be internal connections?
    A6. Yes. The connections installed between the buildings on either side of the public right-of-way would distribute broadband to the instructional buildings of a single school campus, and would be internal connections eligible for Category Two support as opposed to WAN connections eligible for Category One support.

    Huh? Are they assuming that the public right-of-way in this example is not a road? So what is that public right-of-way? Train tracks? Gas pipeline? Canal? (Wait, does a canal count as a stream?)

  2. The ESL provides only one example for determining geographic contiguosity:
    "...a single school with instructional buildings located miles apart are not a single campus...."
    No mention of roads or streams in the ESL or EMO.

    Does the FCC ever define "geographically contiguous"? Not that I could find. But if you check the definition of "LATA" in 47 U.S.C. §153(31), you see that LATAs are "geographically contiguous," and LATAs are lousy with roads and streams and rivers and highways and public rights-of-way of all sorts.

    Seems like we need a new definition of "geographically contiguous," because I don't think it means what USAC thinks it means.