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Tuesday, March 25, 2008

Well, isn't that ESPAcial!

Kudos to the E-Rate Service Providers' Association (ESPA) for their comments to the FCC on eligibility. When announcing the last ESL, the FCC said, "this proceeding is limited to determining what services are eligible under the Commission’s current rules and is not intended to be a vehicle for changing any eligibility rules," and suggested, "those comments not addressed in the Funding Year 2008 ESL may be more appropriately filed for the Commission’s consideration in the general proceeding for the Schools and Libraries Universal Service Support Mechanism in CC Docket No. 02-6." Until now, no one had bothered to take them up on that.

Now ESPA has resubmitted its comments along with a cover letter suggesting that the FCC allow the public to submit suggestions for changes to eligibility, instead of the current policy, which is that only clarifications are allowed. Unfortunately, that would throw off the current FCC timetable, which is to get the draft ESL from USAC in March, sit on it for 5 months, release it (unmodified) in August, allow one week for comments, then make an edit or two over the next 2 months, release it in November, and waive its own rule, reducing the time between the release of the ESL from the 60 days (as set in the Third Report and Order) to a week or so.

Resubmitting my ESL suggestions has been on my to-do list for months now, but I don't know if it will ever get to the top of the list. The ESPA submission is a motivator, though.

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