Sun Myung Moon and the E-Rate

Thinking over the "bundled components" NPRM has me thinking about an E-Rate Unified Field Theory, which would unite the rules for:

1. bundled components
2. gifts
3. free services
4. on-premise priority one equipment (O-PPOE)
5. ancillary use
6. cost allocation
7. educational purposes

Some rules I didn't put on that list, and why:

1. 2-in-5: the 2-in-5 Rule should just be dumped
2. 30%: the 30% Rule has already been gutted
3. competitive bidding and bid evaluation: competitive bidding rules should be left to the states
4. cost-effectiveness: this term should be struck from the E-Rate lexicon; the "Cost-Effectiveness Reviews" are really Educational Appropriateness Reviews (or "'Whoa! That's out of hand!' Reviews"); the FCC's cost-effective guidelines (from the Ysleta Order) would be unnecessary if service providers were forced to obey the Lowest Corresponding Price rule

I'd like to add the Eligible Services List, but I don't see a way to include that in a single rule.

The first thing that comes to mind is Funds for Learning's proposal to create a per-student cap on funding.  It creates a simple rule that reduces the need for all the above rules, since the cap promotes the fairness that is the ultimate goal of the above rules.  But to make all the above rules unnecessary, we'd have to take the FFL plan to the extreme, turning the E-Rate program into something more like EETT: "Here's a chunk of money, based on the number of students and percentage of low-income students; spend as you see fit on transmitting voice, video and data to classrooms."  No one is proposing that, especially not consultants, who would become E-Rate dunsails.

I'm a big fan of Ancillary Use.  I've suggested using it to replace the stupid O-PPOE rules.  I've suggested using it to winnow out bundled services and free services.  And the ancillary use rule is just part of the cost allocation rule, so we've got 1, 3, 4, 5 and 6 covered by the current cost allocation/ancillary use rule:
"If a product or service contains ineligible components, it is fully ineligible, unless:

1. The cost of the ineligible components can be identified and removed from the funding request, or
2. The following are true of the product or service:
1. the product or service is a standard product offering, and 
2. a price for the ineligible component cannot be determined, and
3. the product or service the most cost-effective means of obtaining the eligible functionality without regard to the value of the ineligible functionality.”

That leaves Gift rules and Educational Purpose rules.  I can't see a way to work those in right now.  I'll have to sit on that a bit.