The starting pistol is loaded

The ESL for 2012 has been released!  Long live the ESL!  I haven't read the whole list yet, but the FCC says they mostly adopted the draft ESL, and I already commented on the draft.

The FCC also authorized USAC to open the filing window no earlier than November 28th.  First, kudos to the FCC for obeying their own 60-days-between-approval-of-ESL-and-opening-of-window rule.  Two years in a row!  But more importantly, it's time for the annual window pool.  When will it open?  When will it close?

My bets:
Open: January 2nd
Close: March 22nd

Lots more ministers and clerics

OK, so I bemoaned the fact that the E-Rate Correction Order is being used to tighten what kind of errors can be corrected after a form is filed.  In their recent "News for the Week," E-Rate Central pointed out that the E-Rate Correction Deadline Order actually says that more ministerial and clerical errors are listed in the Ann Arbor Order.  That order lists the following ministerial and clerical errors:

1. failing to timely notify USAC to correct a USAC clerical error,
2. entering on their FCC Form 471 the wrong
• FCC Form 470 number,
• billed entity number
• billed entity number/worksheet number 
3. entering the wrong name or service provider identification number (SPIN)
4. entering the wrong expiration date for a contract
5. erroneously characterizing the purchase and installation of equipment as a recurring service
6. making a calculation error
7. entering the monthly charge as the annual charge
8. entering the discounted annual price rather than the pre-discount annual price
9. entering the amount that a service provider was mistakenly temporarily charging rather than the contracted monthly rate
10. miscalculating its discount rate
11. failing to separately list a building where equipment was to be located
12. failing to enter a request for telecommunications service that was clearly indicated on its item 21 attachment
13. basing its block 5 funding requests on the wrong FCC Form 471 block 4 worksheet
14. selecting the wrong term or service
15. selecting the wrong category of service in its FCC Form 471
16. making a typographical error in recording the cost of ineligible equipment in response to a USAC request for additional data
17. failing to follow the correct procedure for modifying its FCC Form471
18. mistakenly providing the wrong documentation concerning a purchase
19. describing the service it purchased as for its entire district when it was only intended to serve a single elementary school
20. omitting a service from a service substitution request
21. entering the wrong application number on the certifications it submitted 
22. failing to press the submit button to submit its otherwise completed application

Now if we could somehow get PIA to accept all of the above as minesterial and clerical without having to provide explanations....

Not the worst name

I was just skimming another Ex Parte to the FCC, and it struck me: part of the Universal Service Fund is something that is called the "High Cost Program."  In the past, I have always taken it as intended: a program to subsidize telecommunications in places where the cost of providing telecom services is high, ergo the High Cost Program.  But today it occurred to me what that name looks like to someone who doesn't know the USF.

If I were looking to get rid of expensive government programs, the "High Cost Program" seems like a really good place to start.

So while I often complain about the name "E-Rate" and its controversial spelling, things could be worse.