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Monday, April 08, 2013

Fruitless searching

One last note from the USAC annual report.  One of their footnotes sent me on a tirade that I decided needed it's own post:

Users struggled with the Search Posted 470 Information tool because of its limited capabilities for searching and reporting results.Instead of making changes to the existing tool, we created a brand new one with expanded search options and multiple reporting formats.The new Download 470 Information tool gives users access to the information they need, the way they want it.

How did I miss the announcement of the new 470 Download Tool?  Maybe because I don't consult for service providers.  So let's take a look.  Yup, it's an improvement.  Maybe a big improvement for some users.  But I don't see how searching and reporting are improved.  Why not?  Because there is no standardization across 470s.  I just downloaded a pile of 470s, and let's look at what applicants called local telephone service on their 470s:

  • Phone Services
  • Local Voice Service
  • Local, Long Distance & Intralata phone service
  • Local and/or long distance phone svc
  • local and long distance voice service
  • Telephone Land Lines
  • Local Telephone service
  • Local Phone and Long distance servive

Honest to God, those are the first 8 requests, so they're a kind of random sample.  Now what kind of search could I make that would return all 8 of those requests?  Misspellings and abbreviations aside, there is no common term for this service.  Searching for "local" would find 6, but would also return "local area network,"   etc. "Phone" would find 5 (assuming your query would catch the "phone" substring in "telephone"), but would also return cell phones and phone systems and so forth.  And let's not get started on whether the lines need to be POTS, Centrex, PRI, SIP, hosted VoIP, etc.

So no, the new tool doesn't give me the information service providers want in the way they want it.  Because the form doesn't collect the information in the way they want it.

The Form 470 needs to have a series of pull-down options like the online Item 21 Attachment (only more attached to reality).  Once you choose "Local phone service," then you have a second pull-down that shows "POTS, Centex, etc."  Then you put in a number of lines.  If you want some POTS lines for your elevators and alarms, but hosted VoIP for desk phones, you need to use 2 separate lines on the 470.  What's that?  I'm adding complexity?  No, I'm revealing complexity that exists.  Like all the forms, the 470 hides the complexity of this program.

Currently, the Form 470 is completely inadequate as a tool for creating a fair and open competitive bidding process.  The only thing it does is create worthless spambids, followed by spam not related to the E-Rate, followed by virus attacks and sales cold calls.

How could the problem be fixed without increasing complexity?  Get the FCC out of the business of regulating the purchasing process.

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