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Friday, August 17, 2007

No comment

Since I have only opinions, not facts, I won't be submitting a comment for the about the latest Request for Comment from the FCC, about the request by Louisiana and Mississippi to extend the special Katrina relief rules. The states have asked that all affected schools be kept at 90% for 2007 for Priority 2, and that the funding be expanded to cover all Prio 2 purchases, not just those necessary to return schools to pre-Katrina levels.

OK, I can definitely see how schools would still be rebuilding, so it does make sense to extend the rules. But I'm opposed and here's why:
  1. Expanding the "relief" to include any equipment a school cares to purchase because the school was damaged is going beyond even the original scope.
  2. The E-Rate is not the right vehicle for relief. I just don't see the connection between interstate telecommunications and hurricanes.
  3. Giving anyone a 90% discount is a bad idea: it causes waste, fraud and abuse. Giving a 90% discount to a broken school, a school scrambling to get back on its feet, a school where administrators are strained to the limit, is just asking for it.
  4. For 2007? Now's the time to grant relief for 2008-2009. That way there will be some predictability for applicants.
  5. If the FCC really wants to do this, they should take some of the rollover funds (the original estimate was $132 million) and set it aside for Katrina relief, and let damaged schools apply for 70% funding of internal connections until 2009-2010, or until the money runs out, whichever comes first.

But I find it hard to tell the FCC that I think the people affected by Katrina don't deserve special consideration, so I'm keeping my comments here.

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