Search This Blog

Friday, March 02, 2012

One down, two to go

Pamplona, eat your heart out: once again, it's time for the annual "Running of the Notification of Form 470 Posted but No Associated Form 471 Letters."  Back when these first came out in 2008, I had four gripes:
  1. The envelopes were not color-coded.
  2. Since almost every applicant gets one, it's spam.
  3. It doesn't actually convey useful information.
  4. It's a waste of paper.
First, the good news: I can strike #4 off the list!  Today's notification came by email.  And that means I can take #1 off, too, since emails can't be color-coded.  But I'll still take the opportunity to restate my opinion that all correspondence should come in an envelope that is the color of the paper inside.

OK, so at least this useless correspondence is not using up colored paper and white envelopes.

But the other two complaints are the real meat of the matter.  In Paragraph 24 of the Bishop Perry Order, the FCC commanded: "USAC shall also develop a more targeted outreach program and educational efforts to inform and enlighten applicants on the various application requirements.... USAC should also notify applicants that have filed an FCC Form 470, but have failed to file an FCC Form 471 or its certification by the close of the filing window."

It's pretty clear to me that what the FCC had in mind: at the close of the filing window, USAC should notify all applicants who had filed a 470, but not a 471.  How can USAC notify "applicants that ... have failed to file an FCC Form 471 ... by the close of the filing window" before the filing window closes?  Instead, USAC notified applicants who had not filed a 471 by March 2nd that they had not filed a Form 471.  As Mel is fond of pointing out every year, 90% of Forms 471 are filed in the last 2 weeks of the window.  So 90% of applicants got this email.  So much for "targeted."

Further, I'll bet something like 90% of applicants filed their Forms 470 after February 3rd, which means that they aren't even allowed to have filed a Form 471 yet.

How does USAC get away with sending out these notifications in direct violation of the FCC's order to send them to applicants who "have failed to the close of the filing window"?  No one has yet failed to file by the close of the window.  No one will have failed to file until March 21st, which is the first day USAC should be allowed to send out this notice.

So kudos on not killing any trees for this useless time-wasting violation of an FCC order, I guess.

1 comment:

  1. The USAC News Brief this week describes the new letter. It was a good description of what the letter is and how it's different from the past. One interesting fact: letters were sent out for 27,500 applications. That's out of 35,000 forms filed. So 79% of applications generated those letters. So more than 20% of applications are filed with 3 weeks left in window. That's surprising; I would have expected a much lower percentage.