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Tuesday, February 24, 2009

What's the protocol?

We've noticed one small change to the online Item 21 Attachment application, and I don't like it.

For FRNs in the Internet Access category, the drop-down menu of services used to have one choice for "Broadband Internet access." Now there are several items like "DSL" and "Frame relay" and "T-1."

I understand why the change was made. In order to approve an FRN for Internet access, PIA always wants:
  1. Number of connections
  2. Bandwidth (speed) of connection(s)
  3. Type(s) of connection(s) (cable, T-1, etc.)

So it makes sense to have the Item 21 Attachment ask for all those things. Up until this year the form did not actually ask for any of that info. You were just supposed to put it in the "description" box.

I agree that the current method of collecting data makes it useless for any kind of analysis, so I suppose it's good that the form now asks for type of connection. Except it's not quite right. Here are the problems I have with it.

First, the items say "DSL" and "Frame relay" not "DSL Internet access." OK, anyone techie will figure out what's meant, but I guarantee at least one applicant is going to see "Frame relay" there and think that the frame relay circuits connecting their buildings should be in Internet Access, which is wrong. Even worse, this is going to feed the misunderstanding about the allowability of WANs under Internet Access, which is muddied enough already. The items should be "Internet access: DSL" and "Internet access: T-1" and so on. That way, the list would sort nicely, with all the Internet access items together.

Next problem: not all the possible technologies are there. Here in NJ, many districts are still using ATM, but that is not one of the options. The new trend is to have an Ethernet interface, though I believe the carrier is actually using MPLS to transport those packets. And the cable companies only use cable modems up to a certain point, then they are offering an Ethernet handoff, and I don't know what protocol they run behind it. In more rural areas, satellite Internet access is common, but it's not listed either. The form can't list all the possible transport protocols, but they seem to have missed some biggies. There will always be a need for an "Internet access: Other" item.

Third problem: not all applicants buy the local loop circuit with their Internet access. At that point, it doesn't really matter what technology is being used for the circuit (which is a Telecommunications Service).

Why does PIA want to know what the transport technology is, anyway? It's not like the information is reliable. Most of my clients who have a a 1.5 Mbps ATM or frame relay circuit think it's a T-1 (and the telecom salespeople often call it that), and I wouldn't know what to call an MPLS circuit with an Ethernet handoff, even if MPLS or Ethernet were an option. And few of the PIA people I've talked to have a good grip on this. Who would want the information if it were reliable? Does the FCC want to know how many applicants are using which protocols?

Finally, one of the options on the dropdown is "T-2," which is a 6 Mbps circuit that I've never heard of anyone using (apparently it died in the 1970s with the picturephone it supported). Typically, telcos will sell "bonded T-1s" until you get to 9 Mbps, at which point they switch to a "fractional T-3" (although they're just as likely to call it a "DS-3", which I think is more correct (which makes me wonder why you almost never hear anyone use "DS-1," which would be a more correct description of these circuits than "T-1," I think)).

And why not have boxes for "Bandwidth" and "Number of connections"? If PIA wants that info, the form should ask for it.

Monday, February 16, 2009

This week's horror

So last week I'm in the midst of gathering contracts for my clients so I can file their 471s, and I'm rejoicing over the final demise of the Two-Signature/Two-Date Rule (2s/2d), which I dubbed the Jason Rule because it just kept coming back after the FCC had apparently killed it, and what do I see a trailer for? Jason is back in the movie theaters.

Just a coincidence, I kept telling myself.

Monday, February 09, 2009

The Naughty Step

There seems to be a lot of grumbling around the office about the number of timeouts we're getting while putting in the Form 471. And I hear rumblings in the wider community. It's too bad; I had noticed timeouts disappearing. Has someone at USAC been inspired by the epic timeout battles on Supernanny? At least with Supernanny, when the kid gets "the Naughty Step" (so much quainter than "timeout"), s/he gets an explanation, and gets a hug at the end of the timeout. There are just not enough hugs in the E-Rate program.