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Friday, June 27, 2014

Cap in Hand

Chairman Wheeler acknowledged that "Many are asking us to simply raise the contribution rate and send more money to schools and libraries."  He promised, "I will not hesitate to recommend this should it be warranted."  A recent news report said, "An FCC official emphasized that the agency has not ruled out increasing the overall size of the program if it's necessary to meet the president's goals."

This morning it occurred to me that there is a simple way for the FCC to put their reforms where their mouth is.

Uncap the E-Rate fund.

Uncapping the fund is fiscally responsible.  It increases and decreases the contribution rate as necessary to meet applicant needs, instead of setting some artificial spending level, and then crafting increasingly incomprehensible program rules to fit the number.  Right now, the cap trumps all program goals and priorities.

Think how it would simplify the program to go topless.  Because of the cap, we've got Priority Two and the 2-in-5 Rule.  But think a little deeper: the filing window is only necessary because of the cap.  Funding commitments are only necessary because of the cap.  Without the cap, the list of steps in the application and funding process would be:
  1. Get discounted bills.  
That's the way the program was originally supposed to work.

OK, some applicants might have to let service providers know they're eligible.  If USAC doesn't know what your discount level should be, they might have to ask you.  Oh, and I guess we'd still need a form where you certify away your first-born child.  But the complexity of the application process is a result of the cap.  (Well, a lot of the complexity comes from the FCC's misguided and ineffective attempt to regulate the procurement process of local governments, but I've done that rant.)

At this time of year, what could be more student-centric than pulling off that flat cap and tossing it in the air?

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