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Monday, October 22, 2007

USAC creates more waivers

It's not on the USAC site yet, but a reliable source tells me that USAC has decided that the filing window will open November 7, 2007 and close January 24, 2008. Bad move. That early end date is a bad idea in the big picture, but especially bad for this year.

Big picture: If the FCC wants applicants to certify on the Form 471 that they have "secured funding" to pay the applicant share of costs, then the deadline for the 471 should be in late April or early May, when many applicants secure funding for the following funding year. (Some applicants don't secure funding until after July 1, but I don't know how to help them.) The earlier you move in the year, the earlier you move in the budget formulation process, the more meaningless that certification becomes.

For this year: USAC has been saying at the trainings that the window would close in early February. By closing it in the third week of January, they're going to cause a lot of people to file late. And you know those people are going to request a waiver from the FCC, and they're going to get it, only they won't get it until well into the funding year and it creates extra paperwork for everyone.

I hope the FCC is prepared for the wave of appeals coming.

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