Hmm ... what are the "Other Rules Changes" in paragraph 182 of the 7R&O? Oh, it's only one change, adding a definition for "consortium," and the FCC says, "This change does not alter requirements for applicants and service providers." On to the next paragraph, right?
Let's take a look at the definition. It's at the top of page 123. It says, "Eligible schools and libraries may not join consortia with ineligible private sector members unless the pre-discount prices of any services that such consortium receives are generally tariffed rates." Say what?
Right away I'm thinking about a consortium I worked with that included some non-profits, which was a pain in the allocation, because I had to calculate what proportion of services they were using and remove it from the 471 FRN and the BEAR. That consortium is apparently no longer eligible for E-Rate funding. Then I thought how many large networks include private universities. I did some checking on a few statewide networks. I seems the Alabama Supercomputer Authority, the Utah Education Network and CENIC all include private colleges and universities. So I guess those consortia are no longer eligible for E-Rate funding. Then I got thinking about all those Catholic dioceses that include a college or university.
Well, that doesn't seem to be encouraging consortium purchasing.
I guess this is related to the weird rule hidden in the Form 471:
ReplyDeletehttp://blog.on-tech.com/2011/07/hidden-rule.html
It seems that the FCC is very concerned that the E-Rate program not lower costs for ineligible non-governmental entities. I wonder why.
OK, after perusing 47 C.F.R. a bit further, I see that this is just copying info already in 47 C.F.R. 54.501(c)(1) into 47 C.F.R. 500(d). Consortia with private entities have always been forbidden. Except Washington state, which got a waiver:
ReplyDeletehttp://www.fcc.gov/Bureaus/Common_Carrier/Orders/2000/fcc00113.doc