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Friday, June 08, 2007

Not too little, but too late

So much for my idea of using leftover E-Rate funds to fund the following year's Priority Two requests. Today the FCC sent USAC a letter instructing them to rollover $650 million in unused funds into 2007-2008.

While that's certainly a better decision than rolling it into 2006-2007, I would rather have seen it go into 2008-2009. An even better idea would be to have these rollover decisions made in, say, August or September, before the application season heats up.

If your discount percentage is below 90% and above 70%, then Priority Two funding is a crapshoot. There is nothing the FCC can do about the vagaries on the demand side, but they could at least set the supply side before the beginning of the application cycle. Making these rollover decisions after the application cycle has closed adds another unknown to an already murky calculation that applicants in the 70%-89% range must make each year.

Take a hypothetical small low-income school district with 10 schools. 7 of the schools are at 80%, 3 are at 90%, and the district discount is 83%. Going into the application cycle, the district has to decide whether to break the district-wide maintenance contracts into one group for the 90% schools and another group for the 80% schools, or go with all the schools together in the hopes that Priority Two will be funded down to 83%. Or they could get clever and make a contract covering the 90% schools and, say, 4 of the 80% schools to get an 88% discount.

And when it comes to a district-wide equipment upgrade, they also have to think about the 2-in-5 rule.

And the poor district also has to make a guess as to whether the FCC is going to roll some funds over.

So let's take at least one variable out of the equation: decisions about rolling over funds should be made at the same time the Eligible Services List is announced, so that districts can have that information as they start the application process.

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