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Tuesday, September 09, 2008

Latest rulebook addenda released

USAC is calling them "training materials," and to the untrained eye they look like a bunch of PowerPoint slides. But since the FCC held in the Caldwell Parish decision that something that appeared in a slide shown in a 2001 training was therefore a rule, we have to treat each slide as an addendum to the chaotic, contradictory, ill-defined set of E-Rate rules.

I don't have time to really tear through these now, but here's one that jumped out at me: "You should not renegotiate the pricing with your vendor during PIA review. This is a competitive bidding violation."

Huh? So Joe's Network Hut gives me a bid for a switch for $500, and I select him as the most cost-effective bid, then later Joe lowers his price to $400, that makes him not the most cost-effective bid? I can see how allowing higher prices after the contract is signed could result in abuse, but I don't see how lowering prices can do anything but improve the program.

So now my question is, does renegotiating pricing before or after PIA also constitute a competitive bidding violation? If not, what makes the PIA time so special? If so, it means that equipment purchased under the program will be even more overpriced than it is now, since applicants won't be able to take advantage of the constantly dropping prices on data and voice equipment.

If the FCC is going to treat these slides as rules, shouldn't there be an NPRM on them every year?

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