Search This Blog

Monday, September 27, 2010

Where's that order?

So Thursday was an exciting day, with the big reforms being approved by the Commission. The big question today: where is the order? The other orders approved by the FCC were up on the FCC Web site before the end of the day, but here we sit, 4 days later, and still no order. The News Release gives a list of the big changes, but doesn't give the detail we need.

They can't be tweaking, can they? I mean, didn't the Commission approve exact wording? So we've been waiting for someone to convert the file to a PDF? Send the files to me; I'll do the conversion right away.

One piece of big news, the ESL has been approved. So let's play the window game. The Third Report & Order requires at least 60 days from the release of the ESL to the opening of the window. So if we get the ESL today, the window could open on Nov. 26th. That's the day after Thanksgiving, but not technically a holiday. Then if we got an 80-day window, we're looking at the window closing on February 14th.

However, the 60-day waiting period has been a fiction, and the 80-day window is up to the whim of USAC (per the first Third Report & Order), so I'm putting my money on a February 10th window closing.

Friday, September 24, 2010

Fax desperados

Looks like Solix has a new fax server, or maybe someone finally figured out how to configure the one they had. I think maybe I'm the only person who sees enough PIA faxes and is obsessive enough to notice, but someone at PIA spent time and effort making this change, and I wanted to give that person a shout out, because the new header is better.

It's an improvement in a few ways:
  1. The first page is no longer dominated by an ad for the fax server manufacturer.
  2. The typeface on the header was too big, and now it's smaller. I think it's actually a little too small now, but it's still an improvement.
  3. The header shows the page number as "Page 001," which is an improvement over the annoying "Page %U-001" that was at the top of every page (and was "Page 1 of %U" before that if I remember correctly). Unfortunately, they didn't move to "Page 1 of 8," which would have been very helpful, but anything's better than that %U. I do wish that it didn't say "Page 001," because to me, it's a hint at the chilling possibility that I might someday get a fax from PIA with more than 99 pages.

I do have one criticism, though, and it's actually a significant one: I think PIA faxes are illegal. The Telephone Consumer Protection Act requires that all faxes identify what telephone number they're coming from. It's in black and white at 47 U.S.C. 227(d)(2): "The Commission shall ... require that any such machine ... clearly marks, in a margin at the top or bottom of each transmitted page or on the first page of each transmission ... the telephone number of the sending machine...."

Messages from PIA generally have the reviewer's fax number on the last page, but we should be seeing Solix's fax number at the top of every page.

By the way, "the Commission" mentioned in the code is the Federal Communications Commission, so maybe someone should get on this.

Wednesday, September 22, 2010

Better late. Even better never.

The Department of Education filed a comment yesterday on the NPRM for off-campus wireless. Thank God they filed it two and a half months after the comment deadline, only two days before the Commission is set to vote on it, and after Chairman Genachowski has announced what they'll be voting on. Because this way, there is no way that the FCC can consider their heinous suggestion.

Their comment is all about Internet access for mobile devices. No surprise, they come out in favor, and they actually give a couple of good examples to support their position. I'm at peace with off-campus wireless, as long as E-rate's not paying for the devices. What I find heinous is the suggestion that the DoE put forth for keeping the cost of wireless access from overwhelming the fund: set up a pool of money that would be awarded as competitive grants.

First, the separate pool is terrible. Pretty soon every little industry will want a separate pool, and the balkanized fund will be much less efficient and easier for politicians to target.

But the idea that makes my blood run cold is making part of the E-rate a competitive grant. Of course it would mean more districts driven into the arms of an E-rate consultant, which is good for my bottom line, but it would be:
  1. Terrible for districts, who would have to plan wireless initiatives with funding that's completely up in the air. Since the E-rate doesn't make multi-year awards, would they compete every year? What if they lost in year two?
  2. Terrible for PIA, which would have to start reviewing competitive grants. Administrative costs would soar.
  3. Terrible for the program, setting a precedent which could eventually cause the program to buckle in on itself.
  4. Terrible for the FCC and their goal of streamlining the program.
  5. Terrible for NJ, where we're still a little shell-shocked over losing $400 million in a competitive grant because someone included the 2009-2010 budget in the grant proposal instead of the 2008-2009 budget.

Thank God it comes too late for the FCC to even consider it.

Tuesday, September 21, 2010

Ex Parte frenzy

With all these ex parte conferences, does anyone at the FCC have time to get any work done? For a while there, we saw a Web hosting flurry, but the blizzard these days is all about dark fiber.

As one might expect, the phone companies are coming down hard against dark fiber. Reading between the lines, it looks to me like the phone companies realize they're fighting a rear guard action, and are looking to limit what kind of dark fiber is allowed. Of course they're still saying, "Dark fiber shouldn't be allowed," but lately the main arguments seems to be, "the FCC should study this matter further." (Any time anyone asks the government for further study, I know they're on the losing side of whatever issue, and are just trying to delay.)

I was curious to see what the Communications Workers of America would say, so I actually read all of that one. They had four points, which I would summarize thus:
  1. Don't allow dark fiber. Managing a broadband network is too complicated for the amateurs in school districts and should be left to CWA professionals.
  2. Be sure that applicants include the extra costs to provide broadband over dark fiber as opposed to a managed service.
  3. Protect workers rights and labor standards.
  4. Ensure adequate funding. Increase the cap.

My reaction:

  1. Whoever wrote this point has not sat in the seat of a school tech director. At best, a broadband connection from a telecom company is transparent. You plug your switch into the provider's Ethernet ports at both ends, and away you go. But in reality, the packets you send into that port are wrapped in an MPLS envelope so that they can be shifted to whatever transport protocol the carrier is using, routed over the carrier network, then reconverted to Ethernet at the other end. There's a lot that can go wrong in the carrier network, though I have to say that other than physical failure (a telephone pole going down or an underground cable meeting a backhoe), carrier networks are pretty bulletproof. But with a dark fiber connection, I'm plugging a dark fiber directly into my switch. No protocol conversion, no routing. The only thing that can go wrong is physical. In addition to being cheaper, dark fiber is easier.
  2. Extra cost? What, the cost difference between a 1000BaseT GBIC and an 1000BaseLX GBIC? There is no extra equipment for dark fiber. For a carrier, there is a *lot* that goes into converting a piece of dark fiber into a broadband network. For a school district, the only difference between dark fiber and a managed service is whether the port is copper or fiber.
  3. Now this is the kind of argument a union should be making. However, the political power of unions really seems to be on the wane, so I don't think we'll see any labor protections in the E-rate program.
  4. Hear, hear.

A tip of the hand

The day after tomorrow is the big day: the FCC will consider a Report and Order making some of the changes that have been in all the NPRMs lately. According to the agenda, "The Commission will consider a Report and Order that improves connectivity for students and library patrons, and accelerates the National Broadband Plan’s goal of affordable access to 1 gigabit per second broadband at community anchor institutions across the country, by upgrading, modernizing, and streamlining the ERate program."

The details of the order aren't out yet, but Chairman Genachowski telegraphed a fair number of the reforms in a speech today at a conference in California. I couldn't stand to listen to the speech and I'm too impatient to wade through the transcript, so I'm relying on a news report based on a briefing paper from the Chairman.

According to the news report, the following changes are coming:

  1. cut red tape
  2. increase broadband options
  3. launch a pilot program for off-campus wireless connectivity for learning devices
  4. allow schools and libraries to tap into unused fiber already in place and state, regional and local nets and bypass "more expensive options"
  5. allow schools to offer that fast broadband service to the community so students can access "affordable" high-speed access at home
  6. open the door to "School Spots," where schools have the option to provide Internet access to the local community after students go home

Here's what I think of those changes:

  1. I'll believe it when I see it.
  2. I can't think of any broadband options that are currently ineligible.
  3. News flash: Last year's Eligible Services List says, "A wireless Internet access service designed for portable electronic devices is eligible to be funded if used for educational purposes." Or is the FCC talking about mobile for pilots? That would be new.
  4. Oh, crap. Maybe I'm just a pessimist, but this makes it sound like the FCC is going to make dark fiber eligible only if it's already in place. How on earth is an applicant going to be sure that no new fiber will be laid? And won't new fiber be needed from the applicant's buildings to the first pole at least? Or is this just a way to allow applicants which currently have lit fiber to switch it to dark fiber?
  5. Double crap. Schools should not be in the ISP business. OK, maybe in rural areas. If the order just says that schools can allow remote users to share their Internet pipe, I'm OK with that, but if it does anything to subsidize those remote connections, it will be a drain on the fund to subsidize home Internet access, which is not what the E-rate was supposed to do. I've already blogged about how mission creep might sink the E-rate.
  6. This is just a continuation of a waiver from last February. And don't tell anyone, but a lot of schools have been doing this all along. Think about how many school districts offer some sort of continuing education classes for adults. What, you think they have a separate Internet connection for those classes? I think this is a great idea; the community gets access, and it doesn't cost the schools anything. And parents who come in to use the Internet connection will have more sympathy when their kids complain about how the crappy filtering software doesn't let you go to any good sites.