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Friday, December 19, 2014

We have the dates, but not the rules

At last, the filing window has been announced.  I updated my table to reflect the new dates.

FYESL releaseWindow
announced
Days to
announce
Window
open
 60 days?Window
close
Window
days
200510/14/200411/5/20042212/14/2004612/17/200565
200611/22/200511/23/2005112/6/2005142/16/200672
200710/19/200610/20/2006111/14/2006262/7/200785
200810/19/200710/28/2007911/7/2007192/7/200892
200911/21/200811/24/2008312/2/2008112/12/200972
201012/2/200912/3/2009112/3/200912/11/201070
201112/6/201012/10/201041/11/2011363/24/201172
20129/28/201111/22/2011551/9/20121033/20/201271
20139/27/201211/13/20124712/12/2012763/14/201392
201410/22/201311/20/2013291/9/2014793/26/201477
201510/28/201412/19/2014521/14/2015753/26/201571

What jumps out at me?  Nothing really.  A few mildly interesting things:

  1. This is the latest that the window has been announced at least since 2005.  Not way later than other years, though, and USAC had a good excuse, with the overhaul of the 471.
  2. The same window close date as last year.  I like it.  Imagine if they made it the same every year....
  3. The latest window open date since 2005, which probably means the latest start date ever (I'm too lazy to check).
  4. Only 23 days between the announcement of the window dates and the opening of the window.  Not bad, but it just feels like there should be at least 29 days between the announcement and the window opening, so it would be possible to file a Form 470 after the announcement and still have time to file a 471 on the first day of the window.

So nothing to complain about on this timing, really.  Now if we just had the Second Report and Order and Order on Reconsideration, so we could know what the rules are.

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