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Saturday, December 30, 2006

Block 16 frustrations

I realize that the online forms can't be convenient for all applicants, since we all have different needs, but Block 16 on the Form 470 is starting to get under my nerves. Part of that block is a list of all the area codes and exchanges for all applicants.

First of all, are there any service providers out there actually using this info? Every provider that contacts me has me resend that info, and usually they want the whole CSR.

Second of all, there are blanks for about 50 area codes. That means I have to scroll, scroll, scroll. Even for statewide applications, the state with the most area codes is CA, which has 34 (or maybe it's 36 now). Are there consortia that span state lines and actually use all 50 blanks? I think not. How I wish it were like Items 8-11; you get a certain number of lines (3 is probably enough for 99% of applicants), and if you need more, you click an "Add more area codes" line, and you get another 10.

Can you tell I've been staring at too many Forms 470 today?

Thursday, December 21, 2006

Terminate the terminal server

A new appeal popped up that reminded me of a shortcoming in the Eligible Services List that has had me grinding my teeth for years: terminal servers.

The rules around server eligibility are terrible, anyway. You buy a server to be a Domain Controller in your Microsoft network. Sure, you toss DHCP on there, because some server has to do it. Now the server is spending 90% of its time authenticating users, handing out Group Policies, and all the other overhead that goes with being a DC. Heck, make it the Global Catalog server, too. Now it's going to spend a miniscule amount of time doing DHCP, but hey, the server is 100% eligible. But move DHCP to some other server, and now it's totally ineligible. Ugly.

The really bad part about the server rules is that over the course of their useful lives, servers get repurposed. OK, if you have a server that's doing only DHCP, you can stick that thing in a corner and it will be able to do that job until the motherboard cracks from age or the hard drive seizes up. But an email server is different. Email is a resource hog, so you want a mighty machine doing that. Three years later, it's no longer mighty, so it's time to buy a new email server, and put the old one out to pasture as a file server or backup DC or something. But no, the E-Rate rules say that you have to turn off that perfectly useful server, put it in a corner and not use it for a dozen years or so, at which point it has no value and the district can dump it. (Because state laws don't allow districts to give away useful equipment, and E-Rate rules don't allow districts to sell surplus equipment.)

The solution? Set a useful life of 3 years for a server. The 2-in-5 rule basically says that you can replace your entire infrastructure every 3 years. So expand that rule a bit to say that you can only buy an email server (or servers, if your network is large enough) every 3 years. One Web server every 3 years. One infrastructure (DHCP/DNS) server every 3 years. And at the end of 3 years, the server can be sold, repurposed, whatever.

But back to terminal servers. I still don't understand the eligibility of terminal servers. They've been eligible for years, but for what use? Apparently the only allowable use is to provide a Web browser for thin clients. (I suppose providing an email client would be OK, too.) It's not clear what the eligibility is if the terminal server is providing a Web browser and other applications.

The appeal is from a company that installed a terminal server that provided access to applications. I never thought such a server would be eligible, but the Eligible Services List at the time sure made it look like it was. The current ESL is better, but I'd still like to see it made more specific.

Even better, dump terminal servers off the list. If I can't get E-Rate funding for the cost of a Web browser if it's installed on a client machine (yes, there are browsers that cost money), why can I get money for a server to provide that software to clients? Terminal servers do not facilitate the distribution of data. Thin clients that want to access the Internet send packets to the switches and routers directly. The only thing that that terminal server provides is end-user software.

Saturday, December 16, 2006

My Christmas list

I'd like to invite everyone to post their E-Rate Christmas lists. [Blogmaster's note: an anonymous note here is really anonymous. Unlike the SLD, I can't collect your IP address and trace it back to you.]

Let's see, what would be on mine?
  • COMADs only for Waste, Fraud, Abuse, not errors
  • New online Form 486
  • Even better, no Form 486
  • All FCC appeals decided within 90 days
  • Publish the secret 700-page PIA manual
  • How about publishing 200 pages of it?
  • How about just telling us what triggers a Cost Effectiveness Review?
  • Don't take the Data Request Tool offline at night
  • At least let us know when the DRT will be offline
  • At the very least, let us know that the DRT is offline. As it stands now, you just get a message that no records were found.
  • A "copy" button on the 470 and 471 which lets you import all the info from last year's forms [For most small, low-discount applicants, those forms are identical year in and year out, and for all applicants, many elements are identical.]
  • "Two-signature/two date" finally put to rest
  • Let applicants edit BEARs after they've been sent to service providers, so we can correct errors the service providers find
  • An online tech plan tool that applicants can use, set up so that it will generate plans that the SLD won't later decide are inadequate
  • A list describing the most outrageous requests. You know that PIA reviewers must pass around really hilarious requests. Let us all in on the joke.
  • Block 4 information in the Data Request Tool
  • Registration of consultants
  • The discount matrix topping out at 80% for equipment
  • Dark fiber eligible
  • An "about us" page for the SLD. There aren't that many people there, and I'd just love to see a brief resume for each of them.
  • The same PIA reviewer 2 years in a row
  • Mel Blackwell in a red suit and beard, flying all over the country, handing out Priority Two funding to applicants with a 40% discount. Ho ho ho.

Fix the 486 already!

Arrgh! I've complained in the past about the online 486 requirement that you use Adobe Reader version 5 to use the online Form 486, and I've heard Macs are not supported at all.

Recently I pondered whether version 5 will be available much longer, since version 8 is due out soon.

Now I have a new gripe. I've upgraded to Internet Explorer 7, and it doesn't play nicely with Adobe Reader 5. I would say that most of the time I'm viewing PDFs, a freeze occurs at some point. I'm not talking about just the online Form 486; any time I'm using PDFs, I can expect a freeze. When the freeze happens, it usually freezes all the tabs in that particular IE window, though I can usually (not always) continue to work in other IE windows. At some point, though, I have to force IE to quit, closing whatever windows I was browsing.

The other PCs in the office haven't been upgraded to IE 7, and we'll have to hold off now. But I'm stuck with a gimpy computer just so that I can fill out online 486es. So I'm actually considering buying an entire computer that sits in the office and does nothing but fill out 486es. I'll load it with the most ancient version of IE I can find, put Adobe Reader 5 on it, and just leave it in the corner where whoever is doing a 486 can sit.

Of course, I'll have to put it in our network's DMZ, because I won't be able to get current security patches for it, so it will be very vulnerable to a variety of malware.

How much could it cost to hire some company to create an online form more similar to the 470 and 471? I say the FCC should let USAC suck another $20,000 out of the fund to get it done. Since they'd just be building a new front end to the SLD database, I wouldn't think it would cost much more than that.

Saturday, December 09, 2006

Online BEAR first look

So I'm reading through the latest SLD News Brief about the online BEAR form. blah blah blah, then I read "If you need to review your previous invoices (paper and online), use the Bulk Download feature on the online BEAR."

So I logged right in to check that out. Did I space out during the part of the SLD training where they mentioned that you could use the Online BEAR tool to look at old BEARs? It's very handy for me to be able to look at old BEARs. Now if I could just grab all that data across all my clients. That's one of those features that I would like, but can't expect, since it would help consultants, but not individual applicants, and the SLD should stay focus on making things easier for applicants.

Something seems to be wrong, though: I don't see the approval status, neither online nor in the download. I checked a couple of different clients, BEARs that were approved, BEARs that were denied, and none of them showed the approval status.

Still, though, what an unexpected bonus.

Friday, December 08, 2006


Ever notice how if you "Submit a Question" at the SLD, the email response comes with an email address of It's a common practice for companies to have an email address like that when they want to avoid replies, but in this case I find it exceptionally apt, since the notes that I get are usually no reply at all to my question.

This used to get me burned, until I realized that the folks at the SLD don't have the answers to most of my questions, since they have not been given the answer by the FCC. So in a way, it is more honest for them to quote back some rule that I know than to try to actually answer my question.

Today's example was really bad, though. I asked about co-location and maintenance of co-located servers. My questions were specific yes/no questions. The response?

"Thank you for your inquiry. Here is a direct link to the Eligible Services List:"

That's it. And that response took 24 days to deliver. It took several deep breaths before the urge to send a snitty reply passed.

It would be much better for the SLD to say: "We have no specific guidance from the FCC on co-location. In the past we have denied funding requests for co-location, but none of those denials has been appealed to the FCC. If you apply for funding for co-location, your request will be denied, but we cannot predict what would happen if you appeal that decision to the FCC." That explains the situation much more clearly, and avoids the applicant sending more and more emails seeking clarification that the SLD cannot provide.

Wednesday, December 06, 2006

Web hosting eligibility rumblings

I hear a rumor that the SLD is going to start doing cost allocation for Web hosting the same way they do it for servers. Ick.

First, I have to say that the SLD has to do something because of the "value-added" Web hosts have been providing unrealistic cost allocations.

"Value-added" Web hosts are a good thing: districts pay extra to get a prefab structure for their content. You want teacher homework pages? OK, here are some templates to choose from, and the permissions scheme is set up to allow teachers to publish only to their own pages. Sports schedules? Yup, there's a module for that. So these value-added Web hosts make it easy to have a current, useful Web site. Many of my clients use them, and most are very happy.

But let's get real about the cost allocation figures. Go to any normal Web hosting site(1&1, GoDaddy, etc.), and the costs range from $3-$30 per month, depending on features, etc. You would be hard-pressed to find a hosting plan that costs more than $20 without ineligible features like databases, e-commerce, etc. That's $240 per year.

Meanwhile, the cheapest value-added host I've seen is $2400 per year. Some are running well over $10,000. [Hey, if that's what it takes to get staff to update the site regularly, it's worth the money, and a lot cheaper than hiring a Webmaster.] So the vast majority of the cost comes from the content management system and the service, right? But the value-added hosts claim that 84%-100% of the cost is for Web hosting. I guess the SLD has finally had enough of that.

This new cost allocation guide isn't good, though. They're saying that if you offer a combination of eligible and ineligible services, you divide the number of eligible services by the total number of services. Most value-added Web hosts would be 50% eligible: 1 eligible service (Web hosting) and 1 ineligible service (content management). If they also offer email, now they're 67% percent eligible, since they now have 2 eligible services.

So why is that bad? Well, for one thing, 50% of some of the more expensive value-added hosts is still too much. For another, it makes ASPs 50% eligible. Schools that are paying for Web-based fiscal systems would be able to claim 1 eligible service (Web hosting) and 1 ineligible service (application hosting). Now a $30,000 piece of software with a hosting cost of less than $1,000 will be eligible for E-Rate funding on $15,000 of the cost.

A better solution? Perhaps the brightline that the FCC has mentioned, but never implemented. Give a school district E-Rate funding on up to $1,000 for Web hosting. Or to reduce the howls from the larger districts, make it $1 per student. That way the E-Rate doesn't end up paying for lots of Web-based applications.