Search This Blog

Friday, July 27, 2007

30% rule lives on?

So I was perusing some of the denial reasons for 2007-2008, just to get a look at the new FCDL comments with their expanded length, and what did I see: several denials due to the 30% rule. How can this be? The FCC gutted the 30% Rule by requiring the SLD to get applicant authorization for any cost allocations.

And in my experience, PIA has been toeing the line. Every time they wanted to change the amount of one of my clients' FRNs, they asked me if it was OK. So how are these people getting denied? I can think of two possibilities.

First, they asked the applicant if the cost allocation is OK, then got no response. After 15 days, they do the cost allocation and invoke the 30% Rule and all the funding is gone.

Second, they asked the applicant if the cost allocation is OK, without mentioning the 30% Rule, the oblivious applicant OKs the cost allocation, then gets blind-sided by the 30% Rule. I had assumed that applicants agreeing to reduce the amount requested would not be subject to the 30% Rule, but now I wonder.

I hope this is simply a case of a few applicants not responding to PIA requests for confirmation of cost allocations. Because there's no way the FCC, in its current mood, is going to uphold the denial of entire FRNs when the applicant has agreed to reduce the amount requested.

The FCC should just come out and say: "The 30% Rule is bad: it punishes honest mistakes and doesn't save the SLD any work. We're tossing it out."

And while they're at it: "The 2-in-5 Rule is bad: it makes a complicated mess, and hasn't helped spread around Priority 2 funding. We're tossing it out."

No comments:

Post a Comment