Looking ahead to PIA, but not looking forward to it

Now that the new Eligible Services List has been out for a week, I've had time to ponder, "What interpretation might USAC make that the FCC didn't intend?" What has me worried today?  The items listed under categories that have been made ineligible.  I'm afraid USAC is going to interpret what the FCC said literally, and that will result in some decisions that probably don't match the FCC's intent.  Let's go category by category, using the handy list in Appendix B.

Circuit Cards/Components
Taking the broad view, all Category 2 equipment is a concatenation of circuit cards.  I think we can be pretty sure that if you buy a stock router, USAC won't consider everything inside to be ineligible.  But what if you want to upgrade the RAM on that router?  Sorry, that's a circuit card.  What if you want to connect it to fiber?  You'll need to insert a fiber network interface card, which is a circuit card.  Want to get really worried?  Read the definition of "Circuit Cards" on page 30 of the old Eligible Services list, and think about chassis switches.  Your Cisco 6509 is a $6,000 chassis with (ineligible?) circuit cards worth $60,000 or so stuck in it.  I guess since the fan tray and power supply aren't circuit cards, you can get funding on them.  Should we be planning to stack fixed-port switches?  Even then, I guess we won't get funding for the uplink GBICs, since they're circuit cards.

"C'mon," you're saying, "those are components of eligible equipment; of course they're eligible."  Well circuit cards were only ever eligible if part of eligible equipment, so the change is that circuit cards inserted into eligible equipment are no longer eligible.  I don't think that's what the FCC meant, but that's what they said.

Data Protection
Since firewalls and UPS units are exempted, we lost:

• Tape backup: Since servers are gone, this is no loss.
• Proxy server: Oh dear, are we going to get stuck on semantics?  Caching devices generally proxy web requests, so caching servers are proxy servers.  So I'm afraid some caching vendor is going to use the words "proxy" and "server" in proximity, and PIA will deny funding.
• Virtual Private Networks: The FCC wants VPNs excluded, so this should be OK.  VPN functionality is included in a lot of eligible routers, firewalls, and caching devices, so PIA may bring up the issue, but it should be relatively easy to claim ancillary use.

Interfaces, Gateways, Antennas

Since antennas were exempted, the only problem I can see is an unstated rule.  If you read the rules on On-Premise Priority Category One Equipment (O-PPCOE), there is an unwritten assumption that O-PPCOE is equipment that is normally Priority Category Two, but can be made Priority Category One under certain conditions.  If it's ineligible equipment, then it's bundled ineligible equipment, not O-PPCOE, right?  If a CSU/DSU is no longer eligible under Category 2, can it still be O-PPCOE?  I don't see how.  Uh oh.  Every circuit except dark fiber is terminated with some kind of O-PPCOE, and now in many cases, some of that is going to be bundled ineligible equipment.  Oh, the pain.

Servers

I actually think this is pretty clear.  Good riddance.

Software

New rule: Only software supporting eligible equipment is eligible.  

Old rule: Only software supporting eligible equipment is eligible.

That's not an eligibility change.

Storage Devices:

First, my unreasonably precise complaint: every piece of equipment on the eligible services list includes some storage device, even if it's just ROM.  My real complaint: "caching" is storage; you can't cache without a storage device.

Telephone / Video / Voice/video Components

Fine, all gone.

I hope that USAC will be reasonable, but I'm expecting at least one of the worries listed above to be realized during PIA this year.