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Tuesday, September 03, 2019

PIA's newest employee

Check out who is now doing PIA reviews: Commissioner O'Rielly!

This week, he sent a letter to the Superintendent of one the the consortia that he has been accusing of wasting money by overbuilding.

It's basically a special cost-effectiveness review (CER).  CERs from USAC are arbitrary and mysterious enough, but now we have an FCC commissioner dreaming up more requests. We've always been dealing with secret cost-effectiveness standards, but now we have a Commissioner creating his own standards after the application's in review.

Hey, here's an idea: before we start with multi-directional CERs, the Commission should first decide if CERs are allowable.  There are a large number of appeals of CER denials that have been awaiting FCC decision since 2008. Here's my dream: that in deciding those appeals,  the Commission sets clear standards for cost-effectiveness, which are then published every year in the Eligible Services List.

I've said more than once that I don't think that the FCC should be encouraging consortia, but it seems unfair and capricious for the Commission to be encouraging consortia consistently for 20 years, and then suddenly requiring an applicant to justify creation of a consortium and justify its members.  First, the Commission should clearly disavow paragraph 476 of the Universal Service Order: "we should encourage schools and libraries to aggregate their demand with others to create a consortium with sufficient demand to attract competitors and thereby negotiate lower rates or at least secure efficiencies, particularly in lower density regions."  For 20 years, the FCC has been saying "bigger is better," and now Commissioner O'Rielly is asking an applicant to explain why bigger is better.