The FCC's recent global order on technology plan, the Brownsville Order, is a nice try, but the tech planning process is still a mess.
My favorite part is paragraph 12, which says, "if an applicant responds to a request by USAC to provide technology plan documentation and the documentation provided by the applicant is deficient (e.g., is outdated or will expire before the end of the relevant funding year), USAC shall: (1) inform the applicant promptly in writing of any and all deficiencies, along with a clear and specific explanation of how the applicant can remedy those deficiencies; and (2) permit the applicant to submit correct documentation, if any, within 15 calendar days."
This should be the rule for all situations. It often happens that the SLD asks a question that any E-Rate wonk would understand, but which is not clear to educators and librarians, so the answer is not what the SLD is looking for. Often they'll ask the exact same question again, without clarifying. If they don't like that answer, either, then they just deny the FRN. (The East Orange Community Charter School appeal that I filed is a good example.)
I've been telling anyone who'll listen that what they should do is send out a letter saying, "You're about to lose funding, and here's why." Then explain in plain English (or "American," as Mel Blackwell likes to say), why they're going to lose funding.
The Alpaugh Order comes close in Paragraph 6, requiring USAC to to be specific, but it does not require them to identify deficiencies in whatever documents are supplied.
The alternative is the current situation: applicants get blind-sided by a denial, appeal to SLD and get denied, then appeal to the FCC and have their funding restored. What a waste of applicant, SLD and FCC time.
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