Gateway gets me halfway

A recent letter made me happy, then I got cranky. Following the FCC's instructions from the Alaska Gateway Order, USAC sent me a letter warning me that a 486 might be overdue.

First, the happy: This is the way the program should work: make a mistake and miss a deadline, and you get a second chance. I don't have trouble keeping track of deadlines, since it's all I do, and I have automated systems to keep me on top of things, but applicants who are doing it themselves just can't keep track of all the deadlines. The 486 deadline was very frequently missed, because it isn't the same date every year, and it's a pointless form anyway. So it's nice that fewer applicants will lose funding because of it.

Now, the cranky: This particular reminder came for a 486 that is required because of an operational SPIN change/FRN split. That is, a funding request where the applicant switched service providers in the middle of the year, so the funding needs to be split between two service providers. Because USAC's database only allows one service provider for each FRN, a new FRN has to be created. And then USAC requires a new 486 for the new FRN. Why? It's not a new funding request. "FRN" is not a synonym for "funding request." An FRN is a database record used to record a funding request. An operational SPIN change does not create a new funding request. So a new 486 should not be required. All the certifications were already given with the 486 for original FRN. The service start date was given in the SPIN change. The 486 is just a waste of everyone's time in cases like this. The new FRN should be covered by the 486 filed for the original FRN.