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Friday, July 25, 2014

It's getting wilder and wilder

It looks like the 7R&O has spawned a new beast to add to the funding process hydra, the Wi-Fi-Rate chimera and the GSA minotaur.  I think I'll call it a satyr, since it's small and harmless.

A lot of NPRM commenters opined that applicants shouldn't have to file an application year after year for the same multi-year contract.  The FCC heard and created another application process for multi-year applications.  Oy.

I don't think I will ever use this form.  Because filling out an item in Block 5 to cover a multi-year contract is quick and easy.  It would be really easy if USAC built a "copy last year's 471" button.

What is required on the new form?  The FCC says in paragraph 194:
  1. "basic information identifying the applicant":  To do a Form 471, I just give the BEN and the rest autofills.
  2. "confirm that the funding request is a continuation of a FRN from a previous year based on a multi-year contract": You mean like the Item 15d checkbox on the Form 471?
  3. "identify and explain any changes in...the discount rate": You mean like editing the Block 4 that I can import from last year?
  4. ""identify and explain any changes in...the membership of a consortium": What?!  How can a multi-year contract survive joining or quitting a consortium?  Wouldn't a new contract be required?
  5. "identify and explain any changes in...  the services ordered": You mean like filing an Item 21 Attachment?
So let's see, the new form has Block 1, Block 4 and Block 5.  You know they aren't going to omit all those certifications in Block 6.  And now that we have measurable goals, they're not going to give up on that Block 2 information.  That's all the blocks.

For applicants who have only one FRN, and it's a multi-year contract, maybe this is a minor improvement, but for everyone else, it's a waste of time.

And as with real satyrs, innocents should beware.  Because if you have a new multi-year contract, you'll think that you can use this new multi-year contract form.  But no, you have to file a Form 471 in the first year, and then this new form in subsequent years.  Make that mistake, and the satyr will show its frisky side and you'll be....

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