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Tuesday, November 24, 2009

Small blessing

Check it out: I was using the Billed Entity Number Search Tool today, and forgot to put the % wildcard at the end, and discovered that the % is no longer necessary!

Today's ray of sunshine for the

Don't Doubt Mel

Back in September, when Mel Blackwell predicted that the Priority Two denial threshold would get down to 70%, I doubted him. Now that USAC has announced they'll be funding down to 80%, my doubt is gone.

How was I so wrong? Something is making the FCC and USAC confident that the percentage of FRNs approved will be lower than in the recent past. Could it be there were a huge number of requests from 2008-2009 at 87%, and applicants filed contingent FRNs for 2009-2010, and now that 08-09 is approved at 87%, all those contingent requests go away?

Whatever the reason, now that the funding is over the 80% hump, we could see funding run the table, since there is only about $100 million in requests below 80%. Applicants below 80% gave up on applying for Priority Two funding years ago. Or in some cases, districts dropped some schools from their request in order to get the discount above 80%.

Why did I ever doubt Mel?

Tuesday, November 17, 2009

CIPA update coming, but when?

eSchoolNews has an article about the new CIPA requirements. For those who don't know already, Congress passed a law a ways back requiring student Internet safety training. (How could you not know about it? For months, some companies selling such training have been implying that districts which aren't doing such training now are going to lose funding.)

Well, the FCC finally released an NPRM about it. The NPRM says that the new certification will be on the Form 486 for 2010. I don't think the FCC is being realistic about the timing of this.

First of all, the NPRM says, "the next opportunity for applicants to certify CIPA requirements, including this certification, would be on the FCC Form 486 for funding year 2009." Huh? That deadline was a couple of weeks ago.

Next, let's take a look at the timeline. OK, the NPRM has been released, but I did a quick search of the Federal Register, and couldn't find it published there. So let's say it's published today. The FCC has to wait 45 days for comments. That's January 1, 2010. Now the FCC has to review all the comments, finalize the rules, and approve them. I don't think that's going to happen in a month, but let's be optimistic and say it's released in February. Now the Form 486 has to be amended. Let's be optimistic and say that USAC has already made the changes, and has the form ready in February. Doesn't a change in a federal form have to be approved by the OMB? I know the last change to the 486 was, and I know it took several months. Let's be optimistic and say it only takes 3 months. That's June.

So with my wildly optimistic timeline, the FCC manages to slide the form in by July. Now they're going to have to give districts some time to implement this change, so we'll get another weird multiple choice thing like the current CIPA certification where you can just intend to comply for a couple of years before you comply.

Why not just have the new certification start July 2011?

Thursday, November 12, 2009

My Comeuppance

I have in the past complained about the use "eRate" instead of "E-Rate." But today it was pointed out to me by some E-mpa® colleagues the the FCC uses "E-rate."

My first reaction: that's just wrong. It's a proper name and should be capitalized. We don't say "Universal service fund Schools & libraries program."

Second reaction: surely it hasn't always been this way. Well, I've looked back, and it seems it always was this way. (Actually, I found a 1999 announcement from Chairman Kennard that uses "e-rate," which is just aberrant.)

How unpleasant to be be corrected after my self-righteous correction of others.

I'm still not sure I can bring myself to write "E-rate." It may be time for me to consider moving to a new profession. Or maybe I can start using the catchy USFS&LP.