Part-time student? You don't count.

If I'd gotten around to a full review of the FCC's recent C2 Order, I would have mentioned the problem with excluding part-time students, but Infinity Communications & Consulting did even better, submitting a Petition for Reconsideration.

Basically, the FCC went too far. A few commenters on the C2 NPRM pointed out that having district-wide budgets would simplify the application process for some districts, where students were part-time in two schools in the same district.  True enough.  But for some reason, the FCC went further and said, "In another effort to streamline both the application filing and review process, going forward we will base student counts on full-time enrollment only and eliminate the need for schools or school districts to count part-time students in their enrollment numbers."

I suppose that's fine in states where county-wide districts almost never send students to another district for part of the day.  But not here in NJ (or, apparently, in California, since that's where Infinity is based).  Here in NJ, there are districts that are mostly part-time students.  How?  Well, in NJ, we have more school districts than municipalities.  So way back when, the state created county-wide vo-tech districts.  The model was this: students take all their academic classes at their home high school, and then go to a vo-tech school for part of the day if they want to study car mechanics or cosmetology or culinary arts or whatever.  In NJ, they're called "shared-time" students.  So the vo-tech districts generally had few or no full-time students.  That's been changing at some of the vo-tech districts recently, as the vo-tech districts have expanded into full-time programs, but some of the vo-techs still have a significant portion of "shared-time" students.  Now, the state of NJ reports "full-time equivalent" enrollment numbers to USAC, so a shared-time students only counted as half a student.  That seems fair, no?

But under the new rules, shared-time students can't be counted by either district.

I probably shouldn't point this out, since USAC probably doesn't realize that the state has been including half-students in their enrollment numbers (though they should have realized it, since enrollment totals for a school can be, for example, 232.5).

So how about instead of "simplifying" things by not counting part-time students, the Commission just says, "Whatever the state says your enrollment is, that's your enrollment."