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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.]

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