Waiving in the New Year

I sure hope the good folks over at the FCC got what they wanted for Christmas, because they certainly gave out plenty of holiday cheer. Taking a quick look at recent appeal decisions, the FCC tally since November 23rd:
Appeals granted: 69
Waivers granted: 205
Denied: 1

It's like the heady days after the Bishop Perry Order, when it seemed like the FCC would waive anything.

Another thing that jumped out at me: many decisions came within 60 days of the date the appeal was filed. The fastest I saw was one appeal in the Academia Bautista decision; the appeal was filed on 11/22/10 and decided on 12/19/10. That is breathtaking speed for the FCC. True, that decision also included appeals that were filed in 2005, but it's the holidays, so let's look on the bright side.

More ubiquitous than I thought

Well the applications for the Education Deployed Ubiquitously 2011 pilot program are in. (You can see them by going to the FCC's ECFS (Electronic Comment Filing System) Search for Filings page, type "10-222" (without quotes) into the "Proceeding Number" box and click the "Search for Comments" button.

As of this morning, there were 88 submissions. Some look like duplicates, but it still looks like over 80. So now I guess the Wireline Competition Bureau gets to spend their holidays reading through grant applications. Since earlier documents indicate they are expecting to award funding to around 10 applicants, they'll be playing Scrooge to around 70 applicants.

I'm actually surprised they got so many applications, since it's only supposed to be schools that are already giving students off-campus wireless access.

hraunfoss, we hardly knew ye

Warning, severe E-Rate geek alert. Honestly, I don't know who but me would even notice such minutiae, but I like to think that there are people who are as consumed with this stuff as I am.

Over the weekend, I noticed that I could not access any document which was stored on hraunfoss.fcc.gov. Which is a drag for me, because lots of appeals, orders, etc. were stored on that server. There are probably a couple hundred links on this site to hraunfoss. But I figured someone had kicked a power plug out of the wall on the way to happy hour, and on Monday morning would plug it back in and hope that no one had noticed.

Then I noticed that some of the documents that would have been on hraunfoss were becoming available on www.fcc.gov under a new URL pattern. Uh oh, hundreds of broken links to repair?

But today I've noticed that hraunfoss is alive again, and that it appears that the FCC has left an autoforward for documents that moved off hraunfoss, so if I use the old URL, I get to the new page. (Want to try it? Type in the URL http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-10-2360A1.pdf and look at the URL you end up at.

From a practical standpoint, it would be better for me if hraunfoss went away, since all the applications that normally detect URLs as you type them and turn them into hyperlinks automatically never seemed to understand that "hraunfoss" could be the start of a URL.

But I hope it stays around. For me, hraunfoss always conjured a lovely image of a castle in the Scottish highlands. I liked it much better than it's compatriot, fjallfoss. (Turns out they're both waterfalls in Iceland. Google translator says hraunfoss means "lava waterfall" and fjallfoss means "mountain waterfall," but they also seem to be specific waterfalls in Iceland.)

Now this is the kind of information that should be on E-mpa®'s certification exam for E-Rate consultants.

Start Your Engines!

Well, maybe at least think about kicking the tires. The filing window has been announced: January 11 to March 24.

I'm happy the window is so late.

For those keeping track, here's how the window stacks up against years past, in terms of window length and compliance with the FCC rule requiring 60 days between publication of the Eligible Services List and the opening of the window:

So the window is a typical length. The time between the publication of the ESL and the opening of the window is unusually large, and really, the ESL was announced back in September, so it's almost like the FCC followed their rule this year.

He's no Joe Barton

I'm breathing a little sigh of relief: Joe "Bleed It Dry" Barton lost in his bid to return to chairmanship of the House committee which oversees the E-Rate. Instead, we have Fred Upton, which is a good thing. I think.

First of all, he knows the E-Rate, since he has been chairman of the Telecommunications Subcommittee.

The ALA once characterized him as "very supportive of the E-rate."

The only action I can find (since his part in the 2005 call for serious reform) is sponsorship of a bill to allow schools to get E-Rate funding for emergency notifications systems. Which makes me fear that he'll join in the mission creep that I'm afraid will be the E-Rate's undoing.

Still, that's just a dark cloud on the horizon. For now, the political sun shines on our little patch of heaven.

New window

Three blog posts in one day! It never rants but it pours.

Once again, the envelopes that USAC uses have changed. Now it's an envelope with one big window instead of 2 smaller windows.

My main complaint is the same complaint I've had since 2006: all the envelopes are white. My secondary complaint, which I also first raised in 2006: BEAR notifications are still on white paper, regardless of the funding year.

Here's the weird thing. For FCDLs, each page of the letter is folded, and the folded pages are stacked. So if you grab the cover sheet and pull, only the cover sheet comes out. For BEAR notifications, the entire stack of pages is folded together, so if you pull the cover sheet out, it brings all the pages with it.

The fold-then-stack method is a pain for us. You have to pull out each page, unfold it, restack the pages, then staple them. The silver lining is that you can pull the cover sheet and toss it,* then look through the window and see enough of the first page to tell what's in there.

I'd like to see the next step in saving paper: put the address info on the first page of the letter and get rid of the cover page. I mean, look at the BEAR notification letter: an entire sheet of paper with only an address on it. Then a sheet of paper that has four lines of useful info, followed by just over a page of boilerplate that I haven't read in year. And then a separate piece of paper 6 lines of useful info. (OK, if an applicant has more than one FRN with the same service provider, there can be several sets of 6 lines each.) So 10 lines of information is spread over 3 pieces of paper. It could all fit on one piece of paper.

*Is tossing that cover sheet a violation of FCC rules? The Fifth Report & Order requires that "Beneficiaries and service providers must retain all official notification letters from USAC...." Does that include the cover page? I sure hope not.

The SPIN cycle

The Sixth Report & Order has finally been published in the Federal Register, which means we now know the date that all the changes will go into effect: January 3rd.

Which means from now until January 3rd, we need to do all the SPIN changes we can. If you were thinking about changing service providers any time before July 1st, do it now to avoid the heinous new SPIN change rules.

Item 21 squeeze play

On the Service Provider conference call this week, I heard that applicants will be required to submit Item 21 Attachments inside the window. Currently, applicants are encouraged to submit Item 21s right away, but you don't actually have to submit them until the application goes into PIA review.

The new rule makes some sense, and it won't be a problem for most applicants, especially since I've got to think that Bishop Perry, patron saint of the procrastinator, will force the USAC to allow Item 21s to come in late, either following a warning letter (like a missing certification) or as part of the RAL process.

It is going to be more problematic for us consultants, who have a lot of Item 21s to do. But I'm not a big believer in shaping rules for the convenience of consultants, so I'll just deal with it.

What bugged me on the call was a small technical matter that isn't changing: you can't begin to create an online Item 21 Attachment until the 471 has been submitted. In my presentations on how to file for the E-Rate, I used to recommend that applicants complete the 471, then do the Item 21s before submitting the 471, because sometimes you catch an error in your 471 while you're doing the Item 21s. I no longer recommend that, since you can't do it if you use the online Item 21s, which I encourage applicants to do.

The inability to work on Item 21s until the 471 is filed provides an incentive to do the Item 21s on paper. And no one wants that.

Taking a systems-design look at it, the inability to file the Item 21s before filing the 471 makes no sense. The Item 21 Attachment is a description of the service received. In theory, that should be known at the time the 470 is filed. OK, the Item 21s also have pricing info, which isn't known until the a service provider is selected. But still, service provider selection takes place before contract completion, so the Item 21 Attachment information is known before some of the other information in Block 5.

If USAC's tools didn't limit us, here is the process I would recommend to people who are filing:

1. When you file your Form 470, go ahead and fill out everything on the Form 471 except Block 5. (Of course, you can't do this unless you file your 470 after the window opens.)
2. Start working on the Item 21s. You'll have to revise some service descriptions after bids come in, and you can't do pricing yet, but get the basics in there.
3. After vendor selection is done, complete Block 5 (except for Contract Award Date).
4. Complete the Item 21 Attachments.
5. After contracts are signed, complete Block 5.
6. Review and submit the Item 21 Attachments.
7. Review and submit the Form 471.

While I'm on the subject, here are some previous rants about the Item 21s:

1. Fix the stupid thing where you have to select the type of service before you can import dollars from the 471, which erases the type of service so you have to select it again.
2. Last year, Mel predicted that Item 21s would be publicly visible. What happened to that?
3. Make the online Item 21 collect all the info that PIA needs.
4. Why do I have to file a new Item 21 if nothing has changed from last year?
5. At least give me an "import last year's Item 21" button.
6. Harmonize the Item 21, which only allows one-time charges for BMIC, with the 471, which only allows recurring charges.

And that's all I have to say about that.