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Tuesday, August 19, 2008

NPRM goes live

Well, the Notice of Proposed Rulemaking (NPRM) about changes to the Eligible Services List (ESL) was published in the Federal Register today, so that means the comment period closed 9/18 and the reply comment period closes 10/3.

I've got to think the FCC intends to include the changes in the 2009-2010 ESL, which I think means delays in the application window. In a normal year, the FCC releases the ESL for comment in July, closes the comments in August, then sits on it and releases it unchanged in late October. If it takes two months when no changes occur, how long will it take to incorporate changes?

Looks like another year of almost no time between the release of the ESL and the opening of the window. And maybe we'll even be facing a shortened window.

What I'd really like to see is the whole window pushed back a few months. I think it's absurd and wasteful (and in most cases illegal) that districts have to select vendors and sign contracts in January for services that won't start until July at least.

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