It's not as bad as it sounds at first. By and large, the SLD does the humane thing and works on Priority One funding requests first. So most people know about their requests for telecommunications and Internet funding within a few months of the start of the year (and would probably know sooner if the FCC didn't change the rules in the middle of the application cycle (not that I'm complaining, since lately the rule changes have been positive)).
And when it comes to Priority Two equipment purchases, most savvy applicants apply 18 months before the time they actually expect to install. So it's an inconvenience, and creates extra paperwork for everyone (for one thing, networking products change significantly over the course of 18 months, so service substitutions are a routine part of the process for equipment). But those applicants who this week will be funded for 2005-2006 requests have until September 2007 to install the equipment.
But there is one area where it's terrible: Basic Maintenance of Internal Connections. These maintenance funding requests are Priority Two, but they are for services. Technology budgets at most schools and libraries are meager. Many of them do not purchase service contracts on their hardware, and just hope it doesn't start smoking. Others are underutilizing their infrastructure because they can't afford the configuration and maintenance they would need to keep it all running. E-Rate funding for maintenance seemed like an opportunity for applicants in low-income areas, but it just doesn't work, because Priority Two requests are never approved by the start of the funding year, and are often not approved by the end of the funding year. So by the time the E-Rate funding is approved, it's too late to take advantage of the funding for maintenance. It's a Catch-22 that needs to be fixed.
How? Well, the best solution might be to move maintenance into Priority One. That would probably spell the end of Priority Two funding, as all the low-discount applicants get Priority One funding for their pricey service contracts. Would that be bad?
But before they do that, the FCC should clarify what is meant by maintenance. Because right now maintenance is the newest frontier for waste, fraud and abuse, and if it goes Priority One, we'll have a gold rush and accompanying lawlessness.
[Warning: a rant begins building at this point.]
The definition has been getting clearer, but we need to have some network engineers who have worked in schools to sit down with the FCC staff and say, "Here are the types of maintenance contracts we have. Which ones are eligible and why?" After a few days, the FCC staff would understand enough about network maintenance, and the engineers enough about E-Rate rules, that we could get a rational framework. The current rules seem irrational and unclear to network administrators. For example:
- Network Interface Cards (NICs) are eligible equipment, even if they're in end user equipment, but what about NIC drivers? The IP stack? At what layer of the OSI model does eligibility end?
- Maintenance on a KVM switch is eligible if all the attached servers are eligible, but what about real life, where a KVM switch is connected to eligible, ineligible and partially eligible servers? Get out your calculator and figure out if it's 7/32 or 9/32 eligible.
- Your Web filter (ineligible, but required) is causing your firewall to lock up. In order for the firewall to work properly, the Web filter needs to be fixed. Eligible? I suppose not, but I couldn't say for sure.
- Adding and deleting users from the email server seems to be eligible, but what about adding and deleting users from the user directory? The answers would seem to be:
- if the directory server is running DHCP in addition to the directory, it's eligible;
- if it's offering file services in addition to the directory, it's not eligible;
- if it's offering both DHCP and file services, it's half eligible;
- if it's offering DHCP, DNS, file and print services, it's half eligible, unless the print services are negligible, in which case it's two-thirds eligible. Maybe.
No comments:
Post a Comment