The FCC won't release the final order until September, probably, but it looks like the Contribution Factor is going to set a new record: 39.3%. Looking at the USAC Fund Size Projections for 4Q25, it seems demand will growing 6.6%, so the rest of the growth in the Contribution Factor is coming from the shrinking Revenue Base.
Time for us all to ask Congress to expand the Revenue Base.
Word from USAC:
A recent change by Microsoft prevented users with Outlook from receiving some email notifications from EPC between July 30 to August 5, 2025. USAC recommends users check their news feed to monitor any FCC Form 471, post commitment, and FCC Form 486 notifications that may have been missed.
Now you might think I'd rant about the email outage, but I don't fault USAC for that; they found the problem and fixed.
No, I'm going to rant about the recommendation to "check their news feed." To which I say: which news feed?
As a consultant, I have news feeds for:
There may be some others I'm not thinking of.
Some notifications make sense: RNLs, RALs and FCDLs appear in the news feeds for both the organization and the relevant form. But why don't FCDLs appear in the feed for each FRN? Nothing seems to appear in the FRN and FRN line item news feeds, so why do they exist?
But RFCDLs do not appear in the news feed of the form(s) to which they pertain, only in the organization's feed. Appeals, too.
In the case of a consortium, the notifications appear in the consortium's news feed, but not in the feeds of the organizations which belong to the consortium.
You know what I use news feeds for? Absolutely nothing. If an email gets lost, we'll pick up whatever the notification was about in some other way.
Want to give Congress a piece of your mind about the E-Rate program? Now's your chance.
The Congressional Universal Service Fund (USF) Working Group has put up a form to submit comments. (You can also email comments to USFWorkingGroup@fischer.senate.gov.) The questions are pretty wide open, so you can let Congress know how you feel on any USF-related topics.
For me, nothing springs to mind for the questions in the Effectiveness section, but the Reforms section has my mind whirring.
The first question:
What reforms within the four existing USF programs would most improve their:
- Transparency;
- Accountability;
-Cost-effectiveness;
- Administration; and
- Role supporting universal service?
Transparency: How about making public the 700-page book of procedures for handling applications?
Cost-effectiveness: Cut the top discount rate to 65%.
Administration: Stop making applicants go out to bid for $1,000-a-month Internet. Wait, what am I saying? Get the FCC entirely out of the business of regulating the purchasing practices of local government entities.
Role supporting universal service: Triple the C2 budget for applicants. The current level is completely inadequate.
Second question:
Looking just at the E-Rate, getting the FCC out of regulating purchasing would help cut waste by allowing schools to have service providers suggest configurations before going out to bid; applicants could choose the most cost-effective configuration, not just the only configuration they happen to know of. I think requiring electronic deposits for reimbursements has made fraud much more challenging. To cut fraud further, require that applicants use an E-Rate management professional; since E-Rate is all we do, we can spot shady deals, and since our entire livelihood is the E-Rate, we steer well clear of fraud. To cut abuse (and waste), cut the top discount to 65%.
Fourth question:
What actions would improve coordination and efficiency among USF programs and other FCC programs, as well as broadband programs housed at other federal agencies?
Oh no, don't tell me overbuilding is going to come up in Congress, too. Seriously, I can't think of any efficiencies to be gained by coordinating the E-Rate with the other USF programs.
Sixth question (I skipped #5):
Is the USF administrator, the Universal Service Administrative Company (USAC), sufficiently accountable and transparent? Is USAC’s role in need of reform?
According to the FCC's response when I made a FOIA request, USAC's routine processing of applications is a law enforcement action, so their procedures are secret. Make those procedures public.
That's enough ranting for now.
The FCC just released a new report setting speed standards for broadband to be considered "advanced telecommunications."
Of course, I skipped to paragraph 14, "Schools and Classrooms." They plan to keep the status quo, which is a short-term goal of 1 Gbps per 1,000 students, and no long-term goal. That short-term goal seems fine to me, but I think we should have a long-term goal. Long-term goals are important in generating long-term progress.
And the reason for not having a long-term goal is, in my view, spurious. They claim that the goal of 1 Gbps down / 500 Mbps up would not be technology-neutral (in particular, excluding wireless and satellite technologies). It's true that wireless and satellite are not currently able to meet the upstream speed of 500 Mbps, but that doesn't mean the standard is not technology-neutral. You know what other technologies can't make that speed? DSL and ISDN (T-1s). Should we restrain the goals so that we don't leave those technologies behind? No. We push for higher speeds, and as some technologies prove unable to scale, they fall by the wayside. If wireless and satellite can't keep up with future needs, then we'll cease to use them.
How to set the long-term goal? I'd start by looking at how the short-term goal has evolved. I haven't looked at the data, but my guess is that we'll be multiplying bandwidth use 10 times over the course of 5 to 7 years. So let's say the long-term goal is 10 Gbps per 1,000 students by 2032. That goal is completely guesswork, but you know what? It's better than no goal.
The first order from the "Delete! Delete! Delete!" docket was just passed by the FCC. According to the press release, the order removed "11 outdated and useless rule provisions—covering 39 regulatory burdens, 7,194 words, and 16 pages." The rules covered things like "telegraph, rabbit-ear broadcast receivers, and telephone booths."
Who wouldn't agree to that? Well, Commissioner Gomez, for one. The lone Democratic commissioner voted no. Why? Was this just "the Republicans are for, so I'm against it"? Not according to Commissioner Gomez's statement. Her concern is procedural. She wants each rule to be published as an NPRM (which maybe they should call an "NPRD!D!D!") before any changes are voted on.
I have to agree. I was thinking about my own suggestions for D!D!D!, and I thought, "I hope they ask for more comment before they take any of my suggestions." Because I'm brilliant and all, but even I can't think of every possible consequence of a rule change. That kind of thing needs crowdsourcing.
In this case, it sounds like the Commission went after truly obsolete rules, but I hope that in the future, they'll ask for comment on any changes they're planning to make, because even in obsolete rules, there may be some line that is important to a current service.
Look who's getting a cap now. FCC Chair Carr had requested a $26 million dollar raise for the FCC, but the House said: "No, you'll get $390.2 million and like it." Just like last year and the year before.
This doesn't affect E-Rate funding directly; the Universal Service Fund is separate. But it does mean the FCC won't have any more people to work on the E-Rate. Which, depending on your level of pessimism or optimism, might have meant the FCC making more rules for the E-Rate or might have meant faster processing of thorny appeals.
Watch tonight's Late Show with Steven Colbert. He gives us a new way to pronounce "FCC." Hint: it will be bleeped out.
