Search This Blog

Thursday, July 19, 2012

The promise of a projection

Well, that was quick.  Yesterday, the FCC ordered USAC to rollover $1.05 billion in unused funds into Funding Year 2012-2013.  How quick?  Well, it was just 8 days after USAC announced it had $1.05 billion available.

But wait a minute, take a close look at that USAC announcement.  It seems to be saying that on August 2nd, USAC will be sending the FCC a projection of funding through the end of September, and that projection will have $1.05 billion in unused funding.

So the FCC just approved a rollover based on the promise of a projection of available funding.

We are a long way from the rules created in the Third Report and Order, now contained in Part 54.507 of 47 U.S.C.: "On an annual basis, in the second quarter of each calendar year, all funds that are collected and that are unused from prior years shall be available for use in  the next full funding year." This order fails on three counts
  1. We are in the third quarter of the calendar year.  (OK, so it's almost the second quarter.)
  2. Since we're already in 2012-2013, the "next" funding year would be 2013-2014.  (Of course, the FCC thoroughly flouted that part of the rule last year with their tossback into a funding year that had already ended.  At least this year they rolled funds into what is almost the "next" funding year.)
  3. USAC has not said it has $1.05 billion in unused funds.  The July 10th letter seemed to be saying that next month it will be projecting that by the end of September there will be $1.05 billion in unused funds.  The rule says "funds that are collected," not "funds that will be projected."
But brushing aside the rules, this is good news for the program, since it means we may get Priority Two funding for 90% applicants with no pro-rating.  However, that may take some time.  As I mentioned earlier, the actual total of P1 requests plus P2 requests from 90% applicants is $3.8 billion, so this rollover is enough only if USAC denies 11% of applications.  That's not an unrealistic number, but I would think that USAC would have to deny 11% of funding before it approves any P2 applications.  Since Solix seems to have been focusing on the slam-dunk applications so far, it's going to take some time to deny that much funding.
Or maybe I'm just being pessimistic again.
Somehow, the whole thing conjures up the Star Trek episode "A Piece of the Action":
"Hey, Oxmix, we need more cash to fund P2 requests."
"Well, here's $400 million."
"You need to find $1.05 billion."
"But The Book says...."
"I would advise yous to keep searchin', Oxmix."
"Oh, right.... Let me check my numbers.... Well, whaddayaknow!  We'll have $1.05 billion in a couple of months."

But I'm sure that's not at all how it happened.

No comments:

Post a Comment