Confirmed: 2-in-5 Rule Fails Again

Just a little tidbit from the latest USAC Board meeting in DC (courtesy of Funds for Learning): "The SLD reported to the Board that they anticipate the final FY2011 P2 threshold to be 87%...."  Given the FCC's willingness to upend the funding landscape willy-nilly, I'm surprised the SLD is even making estimates any more.

As you might expect, I find this to be cause for griping:

1. First, the obligatory "can the 2-in-5 Rule" rant.  Once again, Priority Two funding will not reach 80-90% of applicants.  And it's the same 80-90% each year.  That's 7 straight years of failure.  Absent bizarre rollover gymnastics, the 2-in-5 Rule is totally ineffective in spreading the P2 wealth.  Worse, the 2-in-5 Rule is harmful.
2. The second half of the sentence I quoted in the opening: SLD "did not make an official recommendation to drop the threshold below its current 90% level.."  So here we are, more than halfway through the year, and we still haven't even moved the denial threshold below 90%.  So far from my dream of setting the P2 threshold before the start of the funding year.

So what should the FCC do right now?  Well, it's a little late, but they should set the denial threshold for FY 2011 at 90%.  That would allow applicants with discounts less than 90% to fling up repeat P2 requests for 2012.  Then set the denial threshold for 2012 right now.  Be conservative, set it at 88%.  See how that goes, and gradually the FCC will be able to set the denial threshold when they release the Eligible Services List.  Imagine.