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Tuesday, April 15, 2008

The latest secret rules

The FCC approved the Funding Year 2008 Program Integrity Assurance (PIA) FCC Form 471 Review Procedures on April 10th. The glass half-full view would be that now applications can be approved. But for me, it's more than half empty. First of all, why did applicants have to submit applications by February 6th if the procedures to process those applications had not been finalized by then? PIA has been reviewing applications, I know, but without an approved set of rules, they have been operating on presumptions. There should be a rule that applicants don't have to submit 471s until the rules for processing those 471s are final.

But what really galls me is that the procedures are entirely secret. I don't know how big the procedure book is this year, but for 2006-2007, it was 700 pages long. Which, as I've said before, means most of the rules for the E-Rate program are secret. This for a program where most of the funding requests are for transfers of less than $3,000 from one public entity to another. Do we really need such a large set of secret rules to administer that program?

And those are just the rules for processing 471s. I don't know if the procedures for processing 486es or BEARs are approved by the FCC, but there's got to be a couple of hundred pages there.

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