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Wednesday, February 26, 2014

Really student-centric

I keep hearing people say "student-centered" when talking about E-Rate reform.  But they generally aren't really focusing on the student.  Here's how we could actually focus on the student.

When considering the eligibility of a service, look at how often the service is used by students (or library patrons).  Do districts ever give pagers to students?  No? Pagers are ineligible.  What percentage of cell phones are given to students/library patrons? 1%?  Toss cell phones.  What percentage of phone calls are made by students/patrons? 2%?  Toss voice out of the program.  Do you have student/patron email accounts on your email server?  No?  Then your server's not eligible.  Is your Website designed for students to use, or is it more for parents/staff/community members?

The same goes for locations.  Office buildings should be tossed out.  NIFs like field houses should stay in, since they're used mostly by students.

I don't want to propose cost-allocation based on percentage of student use, but as the FCC considers what to toss out of the program (or demote to a lower Priority), I think they should consider how much of the service is used by students.

Nix the NIF

The program reform idea from this morning's shower: in addition to freeing up funding by kicking services out of the program, the FCC should free up funding by kicking locations out of the program.  If the goal is to bring broadband to 99% of students, why are we funding Non-Instructional Facilities (NIFs)?  NIFs don't bring broadband to students.

If voice gets tossed out of the program, it won't make much of a difference.  Digital transmission service from an eligible location to anywhere is eligible, so the WAN link(s) from the NIF to the rest of the district are eligible.  And if the district's main Internet connection comes into the NIF, then it can be applied for as a district.  To simplify things, I'd say that the E-Rate will not cover separate service for NIFs, but a service shared between a NIF and eligible locations should be eligible.  So if your NIF has its own Internet connection, that would not be eligible, but if the NIF shares a district-wide Internet connection, cost-allocation would be waived for administrative convenience.

That's as far as I got before the hot water ran out.

Tuesday, February 25, 2014

Creeping to 2.0

E-Rate Central's latest newsletter includes the first hints at what might be in the NPRM that Chairman Wheeler said would be coming out soon.  To quote E-Rate Central:
Based on the FCC staff’s outreach last week, it is expected that the forthcoming public notice will focus on the following five areas:
  1. Options for revising Priority 2 funding allocation rules to promote broadband connectivity within buildings (think “WiFi”). Based on last summer’s NPRM and related comments, options are likely to include:
    1. Cyclical funding of Priority 2 for all applicants;
    2. Changing the 2-in-5 rule to 1-in-5; and/or
    3. Providing a specific amount of annual funding per applicant, perhaps on a per-student basis.
  2. Options for encouraging Priority 1 broadband connectivity to underserved schools and libraries. This might include additional funding for installation charges as a means of making recurring monthly costs more affordable.
  3. Consideration of the ongoing eligibility of voice services, including cellular.
  4. Strategies for driving down network costs through more cost-effective purchasing methods and/or funding for neutral third-party network design assistance.
  5. Possible funding of demonstration projects involving bulk purchasing and network design.
Of course I'm going to give my opinion:
  1. If the Commission wants to dedicate more funding to WiFi, then they need to put a high Priority on it.  Why not make broadband Priority One, wireless access points Priority Two, etc.  And cut the top discount levels, to free up more funding and encourage applicants to think about the money they're spending.
    1. Really?  The Dinner Table Rule?  I originally proposed it as a joke, and now it's actually being considered.  Oy.
    2. Changing 2-in-5 to 1-in-5.  Right: 2-in-5 has been a total failure, so let's double down.  (Or should I say "halve down"?)  For FY 2013-2014, the fund has only about an eighth of what it needs to cover P2 for 90% applicants.  So if we go to a 1-in-8 Rule, we can cover just the 90% applicants.  If we can somehow stop the growth of P1 demand.  At least a 1-in-5 Rule wouldn't encourage applicants to shorten their equipment replacement cycle.
    3. I've already said I'm not wild about per-student funding. As an idea for refocusing the fund, it's spectacularly bad.  Instead of the FCC setting funding priorities, each applicant will set its own funding priorities.  Maybe that will be broadband, but maybe it won't.
  2. I'm not opposed to letting schools self-provision fiber WANs, but if that catches on, then kiss everything else good-bye for a couple of years, because those big upfront payments could quickly swallow the whole fund.
  3. I've already come out in favor of running voice out of the E-Rate on a rail.  And cell phones should go, too.
  4. "More cost-effective purchasing methods"?  Like scrapping the 470 process, which drives up costs?  I don't think third-party network design is going to drive down network costs.  In my experience, professionally designed networks are more expensive, because the top priority for the designer is CYA, which means an over-engineered network.  I'm not saying it's bad to pay more for a rock-solid network.  I'm just saying it won't drive down costs
  5. I guess if the staff over at the FCC has some spare time on their hands and they want to run a bulk purchasing or network design pilot, no harm done.  But unless they have a control group, how will they know if the pilot was effective?  How about before we launch new pilots, we get some analysis of the LOGO (nee EDU2011) pilot?  
So other than tossing voice out of the program, I can't say I like the way this is headed.  If the FCC wants to force applicants to double their spending on broadband, then they need to bring broadband into Priority One, and demote everything else.

Or you know what would be cool?  Different discounts for different services.  For example: We want applicants to install fiber WANs, so you can have them at 50-90% off, depending on income levels.  We hate maintenance, so you can only get 20-50% off that.  Voice? 10-40%.  That allows applicants to get some funding for whatever service they want, but provides a strong incentive to go with the services that the FCC wants.  Best of all, it's so ridiculously complex that demand for E-Rate consultants would skyrocket. 

Friday, February 21, 2014

What's that you say?

The current situation in the E-Rate takes me back to my days as a student in Moscow, when we tried to guess whose star was rising in the Communist Party by watching who stood where atop the viewing stand at state parades.  We were just doing it as a hobby, but the State Department had professional Kremlinologists.  Lately, I feel like many of us are playing FCCologist, and so applicants are getting confusing advice.  I hope I'm clear in this blog that I'm just speculating (and sometimes fantasizing) for the amusement of those who spend way too much time thinking about this program.  My advice to applicants takes a more conservative line.

Reading the latest FCC blog post, I was taken back to my college days, trying to determine what the meaning was behind the words.  As I read along, I was wondering why the post had been made.  It seemed odd for an Associate Chief to be restating ambiguosities.  Then in paragraph five, I found the purpose:
"As we move towards the adoption of an E-rate modernization order in calendar year 2014 ...for funding year 2014, ... the rules of the road are those rules that are currently in place."
As I mentioned last week, some people were advising applicants to apply for Priority Two, especially for WiFi, because maybe the Commission was going to alter the rules to allow them to fund WiFi, and count that towards the Chairman's goal of spending $2 billion on broadband.  With the above statement, the FCC makes it clear that the rules aren't going to change for 2014-2015, and references to changes coming in 2014 do not mean change to FY 2014.  The Associate Chief goes on to say, "As for priority two, we are unable to say whether and at what level such requests will be funded in funding year 2014."  Yeah, well, I think we can safely say that there is not going to be enough rollover to cover P2 for the 90%ers, and the rest of the applicant pool can forget about it.

But let's not neglect the rest of the post.

Paragraph 3 seems to put a fork in P2 funding for 2013.  USAC had already recommended it, but this is the first statement from the FCC about it, and it seems clear there is no stomach at the FCC for pro-rating, so kiss P2 goodbye.

From paragraph 4: "...under the current system, this small group of applicants may have insufficient incentives to seek out efficiencies or limit their requests."  Ooh, that sounds like more support for lowering the top discount levels.  Hooray!  90% is too close to free.

Throughout the post, it's clear that the emphasis is not on bringing broadband to the desktop; the goal is WiFi to the classroom.  Again, no surprise, but it's good to see a consistent message.  And repeating "WiFi" should kill the cell phone companies' fantasies that E-Rate 2.0 would mean giving every student a device with a cellular data plan.  It's a shame that gigabit to the desktop seems to be deprecated (scroll down to the fourth item in the list in this post for more on that), but when the President says "wireless," WiFi is the best outcome.

Don't think I didn't notice the worst thing about the Associate Chief's post: the small "r" in "E-rate" (while using the inconsistent big "F" in "Wi-Fi").  I've said before that I think the small "r" is a conspiracy by a Russian mole.  Is it a coincidence that this blog post took me back to my Moscow days?
[Disclaimer: the Russian mole theory is not even speculation; it's a joke.  Now that the Dinner Table Rule has made it into an NPRM and the latest Request for Comment, I want to be clear about when I'm joking.]

Wednesday, February 19, 2014

Spam fail

Sometimes the spam makes me laugh.  Today we got emails from a major telecom provider saying "Save up to 90% on Internet, phone service and more when you file your E-Rate Form 470 by February 26...."  That message would be more effective if you weren't spamming email addresses that you took from Forms 470 that had already been posted.

Tuesday, February 18, 2014

A light at the end of the black hole?

The FCC is requesting comments on the recommendations from its internal Report on FCC Process Reform. OK, I'll comment.

There is only one E-Rate-specific recommendation: 5.39: Parties Aggrieved by a USAC Decision Must Seek Review From USAC Before Seeking Review From the FCC.  I can see why the FCC is doing this: "Requiring parties to first file appeals of USAC decisions with USAC would reduce the number of appeals coming to the Commission...."  Yes, but not by as much as they're hoping.  Very few appeals are filed as the result of USAC being boneheaded and not doing what it knows it should.  Most appeals are the result of USAC making its best guess on what to do, and the applicant disagreeing that the correct guess was made.  So most appeals are going to end up at the FCC, anyway.  Still, I don't think it does any harm to at least give the USAC appeal a try.  I often appeal to USAC even when I know it will fail, just to see if I can get any more information.

USAC does get one other mention, in recommendation 1.12. "For example, one avenue for increasing speed of disposal of USAC items would be to resolve low-dollar appeals and those that are consistent with precedent with fewer layers of review."  Yes!  Really, how much FCC staff time does an appeal for $388 warrant?  Elsewhere, the report suggests creating boilerplate language.  This should be the standard reply for amounts less than $500: "Fuggedaboutit.  The money's yours.  Signed, The FCC."  Done.

"Recommendation 1.1: Efficient Intake Analysis and Relevant Timelines" looks promising.  I would love to have a timeline for my appeals.  But reading further in, it's clear that the timelines would be kept secret from the public.  So we'd still just get the "We have your appeal.  No decision has been reached yet." response.  Later, they say "Act on Petitions for Reconsideration within 180 days, or deem the petition denied."  Oh, hell no.  It's the bizarro world version of my "a decision in 90 days or your appeal is automatically granted" policy proposal.  If a Petition for Reconsideration filed with the WCB is denied, you can bet it will generate a Petition for Reconsideration the full Commission.  (Don't know about the levels of appeal?  Here's a table.)  And at the full Commission level, it is just a slap in the face to some poor school employee who made a mistake and is hoping the FCC will be merciful and save his job by giving him a waiver, to have the Commission say, "Sorry, we couldn't get around to it.  We're denying your appeal without considering it."

I like "Recommendation 1.21: Increase Tracking Transparency of Pending Items," which includes the idea of "developing a detailed inventory of pending matters, and, over time, making that inventory public."  That's great.  No longer would we have to send appeal status requests, only to get the reply "We have your appeal.  No decision has been reached yet."  Instead, we could just go on the dashboard to see that appeal was received and no decision had been made.

Hey, I've got a suggestion for implementing Recommendation 2.28, which includes the idea that "The FCC staff should review existing data collections to determine if there are collections that should be discontinued."  How about taking a look at Item 26d on the Form 471?  It is a number that can't really be calculated, takes hours to estimate correctly, and is not used by anyone.  A completely useless waste of time.

My takeaway: many of the titles of the recommendations look great, but the substance is either worthless or harmful.  Except Recommendation 1.12, which might have a marginally positive effect.

Friday, February 14, 2014

O'Rielly with a capital "R"

Commissioner O'Rielly has made his first blog post, and it's about the E-Rate.  Let's take a look at what he says, and my ill-considered opinion of it.

But first, the most important issue.  In his first written statement about the E-Rate, did the Commissioner capitalize the "R" in "E-Rate"?  Yes!  He used "E-Rate" 15 times, and capitalized it every single time.  Full marks.  And we are all spared the prospect of this blog snarkily referring to him as O'rielly.  Dedicated grammar geeks will also have noticed that the Commissioner uses "E-Rate" anarthrously.  I'm surprised this isn't more common among E-Rate geeks.  It seems anarthrosity is a government employee thing.

Uh oh.  We're not off to a good start in the preamble.  The Commissioner makes the case that expeditious reform is needed because of waste, fraud and abuse (WFA).  He provides links to evidence of WFA [though I almost missed the links because the FCC's CSS has links in dark blue and not underlined, which are tough for this old man's eyes to notice].  I like that the Commissioner is linking to supporting evidence, but all the instances of WFA in his links occurred more than 10 years ago, which doesn't give me a feeling of urgency.  He also mentioned that internal controls are insufficient, based on a GAO report.  I won't complain that the GAO report is over 3 years old, since I just got around to reading it a year ago.

The main problem with this program is not that a very small percentage of bad actors are cheating or wasting.  The main problem is the administrative burden on applicants, which causes many to forego funding or be denied for funding which they deserve.

Then he lays out 6 priorities.  Here they are with my commentary:

  1. "E-Rate must not increase costs on consumers."  Well, I can't say I like that.  The program is vastly underfunded.  If we're not going to increase income, we'll need to chop expenditures.  So what drastic cuts to the program will the Commissioner suggest?  Let's wait and see.
  2. "E-Rate must be refocused on broadband access."  All right, here we go, let's see what cuts the Commissioner proposes: paging and long distance.  Really?  That's all you got?  First, the total cost of those two is maybe $20 million ($0.02 billion) and is falling every year.  The Fund is several billion dollars short of funding all the services in the ESL for all applicants.  If you want to pay for more broadband without raising fees, then you'll need to toss everything else, including all voice service.  Second, if you cut long distance service but not local service, you open a gigantic, smelly can of worms because so much long distance is bundled, and the E-Rate has a poor track record in teasing out bundled services.  Third, the program is paid for by a fee on interstate telecom, so it seems unfair to have only long distance providers pay in, but only local service get funding.  More broadly, I don't have a problem with the focus on broadband, but isn't a Republican Commissioner going to get in trouble for agreeing so wholeheartedly with the President's mission?
  3.  "E-Rate matching requirements must be made consistent with other federal programs."  Hear! Hear! I don't think there is consistency among all federal programs, but we could at least have consistency inside the USF by making the E-Rate's top discount 65%, like over at Rural Health Care.  I'm all for that.  A 90% discount is too close to free.
  4. " E-Rate funding must leverage the private sector networks and services, not overbuild them."  The Commissioner doesn't want the E-Rate to pay for "duplicative networks."  Yeah, it sounds bad when you say "duplicative."  So instead, let's have E-Rate pay for building "network competition."  I don't think the presence of a single provider is a reason to deny funding for competitive providers.  But I completely agree with the Commissioner's minimum: "schools and libraries should not use E-Rate subsidies to become broadband providers outside of their campuses."  I'm happy to see at least one Commissioner come out against the weird idea of "anchor institutions."
  5. "E-Rate funding must not over supply."  Yes.  I just wish that the Commissioner had come out and said, "Not every school needs 100 Mbps."  I deal with a lot of schools, and in general, an individual elementary school does not generate enough traffic to fill a 100 Mbps pipe.  They probably will at some point in the future, but buying bandwidth is not like wiring a building; future-proofing is a waste.  When you need more bandwidth, you get more bandwidth.  Don't buy 100 Mbps now because you think you'll need it in 3 years.  100 Mbps by 2015 is wasteful for most schools.
  6. "E-Rate program administration must be revised."  Yes.  I have no idea if the Commissioner and I would agree on specific revisions (and his interest in WFA ancient history is not encouraging), but I do agree the program needs to be revised.
So kudos to Commissioner O'Rielly for letting us know what he's thinking about the E-Rate.  And I found more common ground than I expected.  And, of course, he comes down on the right side of the program's most important issue: the big R.

Tuesday, February 11, 2014

Who What When Where WiFi How

Have you heard the rumor going around?  Some in the E-Rate community are advising applicants to apply for Priority Two funding for WiFi for FY 2014-2015, because the President and the FCC Chairman have said they want to make that the focus of the E-Rate program.  I'm not buying it, because the Chairman was pretty clear that they aren't going to make rule changes until the summer.  And while the Chairman did say he was doubling broadband funding, it seems pretty clear that the only "increase" in funding will be the normal rollover.  And if they roll $1 billion into FY 2014-2015, that will probably just about cover Priority One demand.  So I think it's much ado about nothing.

But while I was rereading the Chairman's speech, I noticed an interesting change.  While earlier statements had talked about "wireless broadband," the latest speech refers to funding "WiFi."  That's very good news.

Back when Sen. Rockefeller started all this E-Rate 2.0 talk, I fretted that cell phone companies were going to try to turn the emphasis on wireless Internet to their advantage.  Then the former chief lobbyist for cell phone companies was nominated for FCC Chairman.  And right after President Obama's speech, at least one cell phone provider tried to turn ConnectED into a cell-phone data plan initiative.  I was starting to worry that E-Rate funds would be squandered on inefficiently giving every student a mobile Internet access account, instead of using internal wireless LANs.

The Chairman seems to have put a fork in that.  Let's just hope that it stays clear that the emphasis will be on funding WiFi.

Saturday, February 08, 2014

No P2 for you!

It's almost official: USAC has recommended to the FCC that all FY 2013 Priority Two funding requests be denied.  I don't think anyone is shocked, but I kind of thought the FCC might pull one out of and save P2 for at least the 90% folks.  And I guess they still could, except USAC says they've only got about $600 million to rollover, and they'd need $1,600 million to cover P2 from the 90% crowd.  And I'd guess the Chairman will be saving that rollover to meet his commitment that all P1 applications for FY 2014 will be funded.

P2, we hardly knew ye.  Well, actually, the majority of applicants never knew ye, since P2 funding only ever went to high-discount applicants.  (Yeah, yeah, I know, FY 1999 and FY 2010; don't get me started.)  And lately, even the high-discount applicants only saw P2 funding twice every five years, so they weren't too familiar with it, either.

This is bad news for high-discount applicants, though I've noted that they were able to solve the problem by purchasing costly P1 services to supplant P2 equipment.  It's really bad news for equipment suppliers.  For years, this program has been like a dream for equipment salespeople.  Not only could their clients buy more equipment than they normally would (with the 2-in-5 Rule shortening replacement cycles).  Even better than the increased demand, the 90% discount meant that applicants didn't really care about price.  So salespeople didn't have to trouble themselves cutting their commission to make a sale.

It's also bad news for equipment manufacturers, especially manufacturers who have positioned themselves as high-quality (and high-price) suppliers.  Without that 90% discount, schools and libraries will start looking harder at whether they need to spend twice as much to get features they'll probably never use.  (Phone system manufacturers

So what are equipment sellers to do?  One solution for them is the per-student funding plan.  It doesn't preserve the current all-you-can-eat gluttony of some high-discount applicants, but at least it means some equipment can be purchased at 90% off, benefitting high-margin manufacturers and suppliers.

Wednesday, February 05, 2014

Wheeler of Fortune

Well, Chairman Wheeler's remarks at Digital Learning Day certainly didn't live up to the hype I had created inside my head.

What changes are there for 2014?  Consortium applications will get priority.  That's it.

Yes, he kept talking about extra funding for broadband this year, but that's meaningless, since there is no need for more.  Making $2 billion available doesn't mean $2 billion will be requested.  He did commit to fully funding Priority One requests for 2014-2015, but I don't think anyone really expected P1 requests to go unfunded.

The most interesting thing he said: the Commision will "improve the efficiency of how we treat old applications – appeals, holds, and other outstanding requests.... We will get to work immediately to get those funds moving."  The FCC has been clearing the backlog of appeals pretty well, but it sounds like he really wants to step on the gas.  Time for my "a decision in 90 days or your appeal is automatically granted" policy proposal.

The Chairman also released the schedule on reforms that he had promised during Congressional hearings in December.

First, he wants to have an Order covering structural and administrative changes (based on last summer's NPRM) released this spring to go into effect for 2015-2016.  I like that timetable.

Second, he wants to drop a new NPRM "in the coming weeks" to get more comments on a few issues.  What issues? "[H]ow to appropriately phase out legacy services, including low-bandwidth connections, and reprioritize on broadband."

That brings up what I thought was the most interesting part of the speech: it is clear the Chairman wants the E-Rate to about broadband, and only broadband.  What will be tossed out?  I guess we'll have a chance to comment on that this spring, and probably find out when the Eligible Services List is released in the fall.  Look for a shocking ESL for 2015-2016.

The Chairman putting "low-bandwidth connections" in the crosshairs shows the danger for a few applicants in the "100 Mbps to 99% of students" goal: if you can't get 100 Mbps to your school, you don't contribute to the goals of the program, so we shouldn't spend program funds on you.  All you can afford is 6 Mbps over DSL or 15 Mpbs over satellite or 50 Mbps over cable?  No funding for you!  And because you're such a small school, we can easily fit you in the 1% and still meet our goal.  Of course, it is a 5-year goal, and I kind of think in 5 years, you'll be able to get 100 Mbps anywhere.

So let's see: by the spring, the FCC will clear the appeal/black hole backlog, release a new NPRM, process the 1400 requests from the last NPRM, and release a new order overhauling the application process.  And then the ESL will be completely rewritten by the fall.  WCB now stands for "Working like Crazy Bureau."

Sunday, February 02, 2014

Black Wednesday?

The picture is getting clearer, and I can't say I like it.  Over the past couple of weeks, Chairman Wheeler has been dropping hints about changes coming to the program now.

On January 24, Chairman Wheeler blogged:
the opportunity has opened to use existing funds to immediately begin to expand E-Rate funding targeted to high-speed connectivity to students in schools and libraries. These additionally available funds will begin to be put to work this year for schools and libraries. This will be done without affecting the program’s existing structures and the 2014 program application process that is now underway.
Then in his statement on the State of the Union address, he said:
By applying business-like management practices to E-Rate, we can take steps this year that will make existing funds go farther to significantly increase our investment in high-speed broadband connectivity for schools and libraries....
Now the New York Times is supplying more details, and reporting that more details will be revealed by Chairman Wheeler in a speech on Wednesday.  The things that jumped out at me:
The proportion that goes to broadband service in schools and libraries will increase to $2 billion a year from $1 billion....
[To which the grammar curmudgeon says: $2 billion is not a "proportion."  I think maybe you meant "portion."  A proportion is a ratio, not an amount.]
The changes will not require any additional taxes or assessments....
Most of the redirected spending in 2014 will come from funds left over from previous years. Next year, much of the money will come from changes to the E-Rate program, including the elimination of programs that pay for outdated technologies, like paging services, dial-up Internet connections and email programs that are available free elsewhere. 
The spending will be used to increase available broadband speeds and provide wireless networks in schools....
OK, let's start with growing broadband funding to $2 billion.  Since bandwidth is Priority One, applicants have always gotten as much bandwidth funding as they've asked for.  So the reason that broadband funding is $1 billion per year is because applicants haven't asked for more.  So how is the FCC going to create an additional $1 billion in broadband demand?  I can think of a few ways off the top of my head:
  1. Increase the discount level for broadband.  So if you have a 40% discount, you'd get a 60% discount on broadband.
  2. Set aside $2 billion for broadband, essentially making it above Priority One (let's call it Priority Zero).  That would change cost-effectiveness calculations for some applicants, tipping them toward more expensive solutions which are made cheaper by the E-Rate subsidy on broadband.
  3. Change the eligible services list:
    1. Stop funding non-broadband Internet access.  Tell applicants that the E-Rate will no longer fund Internet connections with bandwidth below a certain cutoff.  That cutoff used to be 3 Mbps, but I guess the President has moved it to 100 Mpbs.
    2. Remove technologies that don't use broadband.  So, for instance, tossing POTS lines and PRIs out of the program would provide incentive for applicants to move to hosted VoIP and SIP trunks, which would increase applicants' need for bandwidth and for more robust Internet connectivity.  (I would say redundant Internet connections, since that is the most cost-effective and widely used way to increase the reliability of Internet connectivity, but the FCC has said redundant connections are a not eligible for funding.)
    3. Allow off-campus use of cellular data plans.  Because if your goal is to increase school districts' spending on broadband, there is no better way than to encourage the use of the wildly expensive model of providing mobile broadband to each student.
    4. Throw open the bundling gates.  If cell phone carriers are allowed to supply a free device with the purchase of data plans, high-discount districts will go for that in droves, since the E-Rate-eligible data plans are close to free.
    5. Allow more flexibility in fiber wide area network contracts.  Let applicants self-provision dark fiber, or allow non-recurring charges to cover the cost of connecting school campuses to existing dark fiber networks.
    6. Include WLAN access points (or other internal network components for that matter) when calculating funding for broadband connectivity.  And find a way to fund them, since there won't be enough funding for Priority Two in 2014-2015.
  4. Expand the definition of broadband.  If you count broadband-related services like hosted VoIP  and Web hosting as broadband, you can make it look like more money is being spent on broadband.
All of them are bad ideas.  Well, #4 is just a little sleight of hand, which doesn't do any harm; the $2 billion target is just political, not needs-based, so accomplishing it by means of a switcheroo is fine with me. #1 and #2 won't come anywhere close to doubling demand, especially because we're already well into the application window.  And #3 would be brutal for applicants.  Suddenly, applicants would have to re-evaluate their technology choices, adjust their tech plan accordingly, then submit a new Form 470.  In less than three weeks.

Let's hope that the FCC is just planning to roll unused funding over into 2014-2015 now, believing for some reason that applicants will be encouraged to spend more on broadband than they have in the past.

OK, now onto the FCC's plan to get $1 billion "from changes to the E-Rate program, including the elimination of programs that pay for outdated technologies, like paging services, dial-up Internet connections and email programs that are available free elsewhere."  Let's see, eliminating paging and dial-up will save, what, maybe $10 million?  Email service might save another $10 million.  If they're also going to throw out email servers (which makes sense if you're going to toss email service), maybe we'd save another $10 million. That's $0.03 billion saved.

But the real concern is the statement that "The changes will not require any additional taxes or assessments."  Does this mean that the FCC has no intention of raising the cap?  Or just that they don't intend to change the program fees at this point?  Because if the FCC is planning to have $2 billion out of $2.3 billion go for broadband, that is going to be a vicious change for applicants.  And there is no way that we're going to get 100 Mbps to every student for $2.3 billion.

I guess we'll know more on Wednesday.