The Chimera takes shape

We're getting more news about the Wi-Fi-Rate chimera, the separate fund-within-a-fund that the FCC seems about to create.  Based on statements from the FCC, the plan for Category 2 (C2, née Priority 2) funding is something like:

1. Each applicant location will get a set amount of funding for Wi-Fi:
1. Schools will get $150/student
2. Libraries will get $1/sq.ft.
3. Small applicants will get a minimum of $6,000.
2. The top discount will be 80%.
3. Applicants will be approved once every 5 years.
4. Applicants who are approved will be allowed to use the funding any time over the course of 5 years.
5. Equipment purchased will be assigned to a location, and cannot be moved from there.

And what do I think of that?

The good:

#2 is a start.  Let's cut the top discount rate to 65% for everything, like they did over at the Rural Health Care program, and for the same reasons.

The bad:

#3 is doubling down on a bad rule.  The 2-in-5 Rule was an utter failure, and drove up applicants costs.  The 1-in-5 will be worse.  Well, except #4 helps there.  5 years is too long to wait to refresh wireless access points, but this whole plan is about giving applicants less than they need, so forcing them to keep outmoded access points isn't the worst of it.

#5 is a nightmare.  How many schools open each year?  How many schools close?  What happens to them?  And what about schools that decrease or increase enrollment?  And given that the discount level is set at the district level, there is no reason for an applicant to be transferring equipment between locations, other than a change in need.  Bad, bad rule.

The ugly:

#4 is a kind of good idea with a bad outcome.  The FCC is saying: "Apply for C2 funding any time.  When you get funded, you will have 5 years to spend the money."  What I will be saying to clients: "If you intend to install equipment any time in the next 5 years, apply this year and keep applying until you get funded."  Why would anyone wait to apply?  Get the funding now, and figure out how you're going to spend it later.

#1 is a so-so idea (per-student funding) gone horribly wrong.  The idea that the funding will be allocated per building is just so wrong.  First, not every building needs the same amount of infrastructure.  Think there will be as much BYOD in an elementary school as in a high school?  Second, in many districts, the main Internet connection is in an administrative building, but there will be no way to get C2 funding to buildings without students.  If the main Internet connection isn't in an admin building, it will be in one of the schools, which means that school will have higher C2 costs, without getting more C2 funding.  Third, in order to keep districts from moving equipment after installation, you need to have rule #5, and I just pointed out the problem there.

Of course, the goal of this chimera is not to deliver what applicants need, but to keep costs down, so the fact that admin buildings and high schools will be underfunded in most districts is only sort of a problem, since the district as a whole will be underfunded.