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Saturday, November 22, 2008

Meet the new ESL, same as the old ESL

Here's the time line:
6/30: USAC sends proposed Eligible Service List (ESL) to FCC. (Actually, that's the deadline; I know that some years, USAC has submitted the proposed ESL much earlier.
8/1: FCC posts the USAC-proposed ESL for comments.
8/1: FCC opens a Notice of Proposed Rulemaking (NPRM) with several proposed ESL changes.
8/14: Comment period closes for USAC-proposed ESL.
8/19: NPRM published in Federal Register.
8/21: Reply comment period closes for USAC-proposed ESL.
9/18: Comment period closes for NPRM.
10/3: Reply comment period closes for NPRM.
11/21: FCC announces that none of the suggested changes will be enacted.
11/25: FCC allows window opening.

First of all, a new record: Two working days between release of the ESL and start of the window. In the Third Report and Order, the FCC created a rule that the application window cannot open for 60 days after the final ESL is posted. The FCC has consistently waived its own rule, but this year, they’ve outdone themselves. And if you consider that USAC has not announced the release of the ESL (I learned of it from a Funds for Learning update), almost all applicants are going to learn of it on Monday morning, one day before the FCC has allowed opening of the window.

I’ve got to think that USAC saw this coming, so they’re probably ready to open the window quick, though maybe not by Tuesday; USAC can set the window opening any time after the 25th and close it whenever they want.

When will the window open, and when will it close? Well, I don’t think USAC opens the window by Wednesday, which runs them smack into Thanksgiving, which means a December 1 window opening. An 80-day window would mean February 19th. That’s later than USAC wants, and a year or two ago, Mel Blackwell said he wanted to shorten the window. So I’d almost bet on a December 1 opening, February 10 closing. That’s a 71-day window. But that would make the time from the release of the ESL to the close of the window only 81 days. So I’m hoping they won’t close until February 19th.

But what about the school district that wanted to implement streaming video this year? A video-on-demand (VoD) server at 90% off, is more cost-effective than a streaming video service. But the USAC-proposed ESL made VoD servers ineligible. So the district rewrites their tech plan not to include VoD servers. Now they’ve got to put the servers back into the tech plan, write a spec, file the 470, wait 28 days, pick a vendor, sign a contract, and file the 471. No matter when the window closes, that’s a rush job. The district is not going to get the best deal that way.

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