Good better bad worse

Monday's FCC appeal decision had some good news, then better news, then bad news, then worse news.

Good news: The FCC is finally taking up the issue of the Cost-Effectiveness Review (CER), the most heinous of PIA procedures.  I can't recall an earlier decision about CERs.  Don't know what a CER is?  Count your blessings.  It's a Kafkaesque review where PIA pretends to investigate one thing, while in fact comparing a funding request to some secret standards.

Better news: All the appeals were granted, not just given waivers.  "We find that the applicants listed in the appendix met the requirements for demonstrating that the costs of the products and services in the funding requests were reasonable based on their circumstances and therefore were cost-effective under Commission rules."  So it's not just the FCC giving applicants a mulligan; they're actually saying the applicants were right and USAC was wrong.  I feel the urge to say, "In your face!" but I will refrain.

Bad news: So after I read the above sentence, I jumped to the appendix to see if any of my appeals were in there, and they aren't.  The real bad news was that the list was so short.  I noted back in 2008 that CER appeals were piling up, but this decision only deals with 8 appeals filed since 2009.  What about all the other appeals languishing at the FCC?

Worse news: There is no "Further, we direct USAC..." paragraph.  We get no discussion of why the FCC ruled the way it did, no hint about whether CERs are proper, whether there should be standards, and what those standards should be, or what USAC should have done differently in these cases.  So USAC has no reason to amend their practices, and if they were so inclined, have no guidance on what changes should be made.

I was able to find most of the appeals, and here's my summary of the denial reasons:

Hondo Valley School District: couldn't find it.
Leak & Watts Services: Nothing specific, just "exceeded the applicant's reasonable needs."
Mel Blount Youth Home: Many things were too high: Cost per student, Number of students per server, Number of students per switch, Number of ports per student, Number of students per WAP, cost per cabling drop & Number of cabling drops per student.
Navajo Prep School: A cost/student of $17,898.75 is too high.
American Internet Group, LLC: $609.52 per cabling drop is too high.
Shiprock Associated Schools:  Again, the vague "exceeded the applicant's reasonable needs."
Step Special Torah Education Program: Two servers costing $21,790 each is too much for a school of 40-50 kids.
Universal/Star International Academics: couldn't find it.

One final non-E-Rate note: doesn't "Leak & Watts Services" sound like a good name for a combined plumbing/electrical company?