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Monday, August 13, 2007

Danger, Will Robinson!

I've been perusing all the comments that people have posted about the Eligible Services List, and I agree with most of what I've seen so far, but I saw one that made me think: "Be careful what you ask for."

The State E-Rate Coordinators' Association (SECA) started with a good premise: applicants should not be punished for accidentally putting the T-1 to their ISP under Internet Access on the 470, or listing the Internet access on their phone bill under Telecommunications Services. And then what do applicants do about Blackberry service? It's a problem.

But I think the solution that SECA suggested opens a large can of worms. Vicious, man-eating worms.

They proposed that PIA shouldn't just look at whether the 470 had the right Category of Service, but should instead look to see if the actual service is listed on the 470, regardless of what Category of Service it was listed in. No, no, no.

I do not want PIA reviewers trying to match up individual items on the 470 with my Item 21 Attachments for 3 reasons.

First, it would take a lot of time. Since there is no standardization of terminology on either the 470 or the Item 21, PIA reviewers would have to waste a lot of time trying to figure out what goes with what. More PIA time on each app means longer waits for FCDLs, and more money for admin overhead.

Second, PIA reviewers would make mistakes. Who could blame a reviewer if s/he sees "trunk line" on the 470, but "ISDN PRI" on the Item 21, and doesn't realize they're the same thing.

Third, PIA would be forced to do make some ad hoc rules about what is allowed on the 470. If I put "data connections for 4 buildings" on the 470, and on the 471 I put "4 T-1 lines" or "leased fiber WAN" or even "purchase of fiber optic cable for 4 buildings on one campus," that's OK, as long as the Categories of Service match up. Would it be OK under the SECA proposal? I don't know. And I don't like going into the application process with even more unknown rules.

I agree that PIA's use of Category of Service to match 470s to 471s is far from perfect, but it beats SECA's suggestion by a mile.

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