Form 470: fix it or dump it

When the FCC did away with the distinction between Telecommunications Services and Internet Access when releasing the Eligible Services List, they said that the long term solution was to amend the Form 470 so that the form had only one section for Priority One.  So it seems we should be expecting an updated Form 470 in the near future.

I've already made the suggestion here (and SECA has suggested to the FCC), that Funding Year should be removed from the Form 470.  I even made it part of my scheme to fix the anti-compeititive mess left by the FCC's SPIN change rules.

Here's another suggestion: Somehow, the FCC needs to hide the contact information on the form, especially the email address.

Today, I got some spam completely unrelated to telecommunications or technology, sent to an email address that was on a Form 470 filed in 2010, and has not been used since.  Actually, I have watched this email address be abused first by companies that got it off the Form 470, then by companies related to those companies, and then someone sold it to a spammer, and now I'm getting all kinds of email.

It's kind of a tough one, though, since service providers should be able to contact applicants easily.  Maybe the new Form 470 could just provide a contact form that sends an email to the applicant, without revealing the email address.  And USAC could keep a copy of those emails, which might help PIA catch applicants who are not running open competitions.

Of course, I have to mention what I would really like to see happen: abandon the Form 470!

It's on

The dates are finally final:  USAC has announced that the 2013-2014 filing window will be December 12, 2012 to March 14, 2013.  The close of the window is creeping back towards February, which I think is the wrong direction, but mid-March is OK.

This year has been very orderly and timely so far: ESL released on time, window announced in a timely way.  Now if the FCC would approve the PIA procedures before the opening of the window, we would have the timeliness trifecta.  But I'm not holding my breath, because the procedures are generally not approved until after the window is closed.

Imagine if the FCC approved the procedures today.  USAC could approve the first applications before the end of December.  Then we'd see more applicants applying early.  I mean, think about.  If you filed on December 14th, you might get an FCDL in January.  So if you had somehow screwed up, there would still be time to file a new470, wait 28 days, and file another 471.

Hey, a fellow can dream, can't he?

No skincrease here

Another Funds for Learning infogram, delightfully short on text and long on graphs.  The second graph shows the troubling increase in Priority One demand, which reached $2 billion this year.  But I noticed something else: a steady decrease in the share paid by the applicant.  In 2000, the applicant share was 33% of the total; in 2012, it was around 25%.

Why?  I can think of a few possible reasons:

1. Climbing poverty rates: in 2000, 11.3% of U.S. families lived in poverty; in 2011, it was 15.7%.  I've mentioned this before.
2. Applicant sophistication: more applicants are using consultants, some of whom know how to maximize discounts.
3. Applicant abandonment: 20% applicants have thrown up their hands at the ridiculous complexity and secrecy to get a few thousand dollars, and left the program.
4. Entry attractiveness:  Among applicants not participating in the E-Rate in 2000, the higher the discount, the more attractive the program.
5. Incentive inequalities: Let's face it, 90% applicants increase their spending at a much faster clip than 40% applicants, because it costs them next to nothing to upgrade to ridiculous bandwidth.

But I guess we'll never know what really caused the decrease in applicant skin in the game.  Unless FFL can turn it into a graph for us.

CER 0, LCP 1

The FCC's latest appeal decision is not ground-breaking, but I found two things interesting.

First, the FCC overturned USAC's denial based on cost-effectiveness because "the services ... were not two to three times the estimated commercial market price."  It is heartening to see a cost-effectiveness review held to the only cost-effectiveness guideline the FCC has given us (from the Ysleta Order).  It gives me hope that the USAC cost-effectiveness witch hunts will end.

Second, the FCC looked at "lowest corresponding price" (LCP)!  I don't recall ever seeing that in an appeal decision.  Maybe the new emphasis on LCP is more than just lip service.  I'll be convinced when a service provider actually gets punished for not giving the LCP.

Another E-Rate Blog

Hey, I found a new E-Rate Blog.  It's by a lawyer specializing in E-Rate, so it's very factual, if not very fun, or very opinionated.  Worth subscribing to, in my opinion.  Even better, the author consistently capitalizes the "R" in "E-Rate."  That's enough to make me a fan.