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Wednesday, July 11, 2007

Set the ESL free

Why is the FCC holding the the proposed 2008 Eligible Services List (ESL) captive? A phone conversation today reminded me that it's time for the proposed ESL to be posted for comment. As I described last year around this time, the FCC should post the proposed ESL in June. USAC delivers the proposed list in the spring, and the FCC doesn't seem to make many changes to it, so why hold it?

The schedule that the FCC has been using is unfair for two reasons. First, they compact the comment period to one week. I'd like to see the proposed list released June 1, with a month of comments and two weeks of reply comments.

Second, the period between the release of the ESL and the opening of the window is too brief. Because after the list is released, applicants have to work out what is going to go on their Form 470, and the 470 has to be up 28 days before the window opens. The final list should be released October 1, with the 471 window opening Dec. 1 and closing Feb. 15.

Release the ESL!

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