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?