The side with the most suits

Let's hope the side with the most suits win in this one. While the FCC brought five people to a recent "ex parte meeting" (think "private audience"), which I think is more than usual, but SECA (the State E-Rate Coordinators Assoc.) brought a whopping 28. What issues brought people from all over to the FCC? And what do I think of them.

1. It seems that SECA asked to have the Form 471 online application go live before the filing window opens. Not a good idea in my mind. I'd rather give USAC all the time we can to add new features to the online form. Mel Blackwell mentioned that they want the online 471 to pre-populate as many fields as possible. If they would be able to have a "duplicate last year's 471" button, I'd be willing to wait until January.
2. Clarification of when FCC rulings apply to all applicants, and when they apply only to the appellants. Yes! Actually, it is usually pretty clear, but it took forever for USAC to acknowledge that the FCC was saying that two dates are not necessary on a contract. More clarity is always better.
3. SECA reiterated the request in their ESL comments that USAC let applicants slide on whether they put the right Category of Service on the Form 470. I don't see how the FCC can go along with this one. If I don't check on the 470 that I want Telecom Services, how are potential telecom bidders supposed to find me? On the other hand, the Form 470 is all but useless as a tool to promote competition anyway, so why be a stickler?
4. "Procedural clarification of status of Comprehensive Reform NPRM." I hope that the 28 people at the meeting will let the rest of us know if the FCC said anything of note about this. [I know some of you SECA members read this blog; how about posting a comment? You can remain anonymous.] This thing is like the Sword of Damocles. Conscientious applicants are starting to file 470s, and a month from now, the FCC could say that 470s are no longer required for FRNs under $3,000 (see paragraph 40 of the NPRM). That's most of the FRNs in the program.
5. SECA requested that the amount of rollover funds be announced before the start of the funding year. I'm all for that. It's not as good as my scheme to use rollover funds to set the denial threshold at the start of the filing window, but it's a big improvement over the current chaos.

Way to go, SECA! But if you know, please tell us if the other shoe from the Comprehensive Reform is going to drop for the 2008-2009 funding year.