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Thursday, May 25, 2006

PIA timing crackdown

While the FCC is telling the SLD to give applicants more opportunity to supply information (in the Fayette decision), the SLD is shortening the leash.

On one of our apps, we got the normal 7 days, then another 7 days (some weeks, you just can't get anyone in the business office to give you the time of day, much less the info you need). Then PIA decided it needed an invoice to support one of the Item 21 Attachments. And I was given one day to respond. The email request went out at 4:23 p.m. on May 24, and the deadline was COB May 25. For a school employee with an 8:00-4:00 work day, this would have meant walking in at 8:00 a.m. and finding that an 8-hour turnaround was required. Better not stay home sick or take a vacation until your app clears PIA.

I checked with the reviewer to make sure it wasn't a typo, and his response was that the allowed response time depends on the number of extensions you've already had.

Savvy applicants who are caught by this new policy will be OK; they'll appeal to the FCC, and the FCC will give them a waiver and tell the SLD to get real. But a typical school employee, who doesn't have time to read appeal decisions in order to gauge the mood of the FCC, will just accept the decision and lose funding.

In general, I'm steamed about this "incomplete answer" response from PIA. We have a fairly standard Item 21 Attachments (and have been using the online Item 21 Attachment for some apps) which is fine for most FRNs. However, for some FRNs, we get a letter saying that our response was "insufficient." In what way was it insufficient? Sorry, can't tell you: "internal controls." Why was a very similar FRN passed through without any extra info? Sorry, "internal controls."

It's frustrating and nerve-wracking to have our applications handled according to a set of secret rules (euphemistically called "internal controls"). And I'm in a much better position than most applicants, because I can see patterns across all the apps we do, and I have years of experience. No wonder the Extended Outreach Site Visits find so much fear: $2.25 billion hangs in the balance, and no one knows what the rules are.

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