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Friday, February 27, 2015

Taking it Personnelly

Well, the 470 season is over.  By and large, it went off without a hitch (not surprising, since the form really isn't new), but I have a gripe.

In general, the form performed pretty well, but there was one pointy exception, and I felt like it was pointed at me.  The "Next" button generally brought up the next page in a second or two, and that little in-page system for picking billed entities was fine.  What was slow?  Picking your consultant.  After you put in your consultant's registration number and click the "Search," you have to wait 30 seconds.  But the wait isn't over.  Now you have to pick an individual employee and click the "Retrieve" button, and wait again.  Sometimes that wait was only 10 seconds, but it was often a lot longer, and a couple of times it dragged on so long that the application timed out, and I had to start the 470 all over again.

Is someone picking on consultants?

Why are consulting company employees listed, anyway?  Why does USAC have to keep track of my personnel?  The contract is between the applicant and the consulting company.  Legally, I do not provide consulting; my company does.  So my company should be listed, not me.

Thursday, February 26, 2015

Major Change in the Neighborhood

The big Net Neutrality Order is out!  Well, not really out, but approved.  We can't see the Order yet, but we do have a press release and statements from the Democratic Commissioners.  (Why no statements from the Republicans?  Maybe they didn't get to see the order until right before the meeting?)

E-Rate's not mentioned, but I spotted a couple of things that affect our little patch of heaven.

First, it looks like the Lifeline program will be growing.  This may be the mission creep I feared back in 2013.  The press release is vague: "Bolsters universal service fund support for broadband service in the future through partial application of Section 254" could mean just about anything.  But Commission Clyburn's statement gets a bit more specific: "The Order enables the FCC to support broadband as a separate service...."  So it seems like instead of getting a subsidy on phone or broadband, Lifeline participants will be able to get subsidies on both.  Look for those companies currently providing cheap cell phone service to add a data plan.

Why do I care?  Because when the size of the Lifeline program grows, the size of the USF grows, which increases phone bills, which raises hackles in some circles.  I've said since the start of the Obama administration that the main threat to the E-Rate is USF overreach.

Which brings us to the second change that touches the E-Rate.  Those opposed to regulating ISPs under Title II pointed out that it would mean that ISPs would have to contribute to the USF.  That could have meant a 15% jump in everyone's Internet bill.  But the press release says, "the Order DOES NOT require broadband providers to contribute to the Universal Service Fund under Section 254."

Hmm.  How will the FCC pay for the increased Lifeline costs and the $1.5 billion jump in the E-Rate cap?  "The question of how best to fund the nation’s universal service programs is being considered in a separate, unrelated proceeding that was already underway."  I have a sinking feeling that in the meantime, the Chairman is planning to further leverage the fund to make up the $1.5 billion instead of increasing fund revenues.  That would mean no rollovers.  Dang, I've been hoping for $3.9 billion plus $1 billion in rollover.

Wednesday, February 18, 2015

Promises and Pai-crust are made to be broken

[Oops.  I shot off my mouth without looking closely, and falsely accused Commissioner Pai of obfuscation.  Is anyone surprised?]

Wow.  Commissioner Pai has not been shy about his frustration with Chairman Wheeler's actions, but now he's taken it to a whole new level.  Today, the FCC site has a press release titled "What People Are Saying About President Obama’s Plan To Regulate The Internet."  It is an assembly of quotes about the Net Neutrality approach in the proposal now floating around the FCC.

At first I thought maybe it was some excerpts from public comments submitted to the FCC, and that it would show both sides of the issue.  No, it quotes taken from the press, all opposed to the regulation of the Internet.  So who put this out?  It doesn't say.  [My mistake.  It does say from the office of Commissioner Pai.]

I still don't think the press release moves the process forward, though.

Tuesday, February 10, 2015

What's in a word?

It's been some time since I complained about the word "entity," but the new $150-in-5 Rule gives some importance to the confusion, so I'll renew my gripe, and my call for a new ID numbering scheme.

Since it's been something like 3 years since I whined about this, I'll recap: the term "entity" is way too vague in this program.  Sometimes it means "organization," sometimes "school," sometimes "campus," sometimes "bookmobile," sometimes "location."  USAC tries to clarify things by creating "billed entities" (organizations) and "entities" (locations), but then it violates its own convention by telling us to put an "entity" (location) in Block 1, when that is clearly where only a "billed entity" (organization) should go.

This was all just a cute muddle until 2004, when the FCC's Fifth Report & Order changed the rules to "require all entities that participate in the schools and libraries universal service support mechanism to obtain an FCC Registration Number."  USAC interpreted that to mean that each location ("entity") needed an FCCRN.  The problem is that each FCCRN is tied to a FEIN (corporations get FEINs instead of the Social Security Number given to "natural persons" (I love that phrase)).  Locations don't get FEINs; organizations (corporations and the like) get FEINs.  So USAC told school districts to create an FCCRN for each school.  Since the district has only one FEIN, districts were actually just creating duplicate FCCRNs.  After thousands (tens of thousands?) of duplicate FCCRNs had been issued, the FCC noticed and clarified that when they said "entity," they meant "entity," not "entity."

Now comes the E-Rate Modernization Order, and removes one quirk of the "entity" issue, while making the definition of "entity" mean serious money.

The quirk it removes?  Well, when you're calculating discount for each location and a weighted average for the district, you can combine or split locations to change the district discount.  In many districts, the Junior High and High School are on one campus, but often have separate addresses, individual NSLP counts, and are considered by the state to be two schools.  Is that one "entity"?  Who knows?  What about a district that runs three academies out of one building?  If combining the entities will nudge the aggregate NSLP percentage over a threshold (a junior high with 80% of kids on NSLP combines with a high school with 73% NSLP, and the combined NSLP is 75%: 90% entity!).  But if the aggregate percentage in the above scenario was 74% (which would give you an 80% discount), obviously you want split them to get a discount of 84% or whatever the weighted average gives you.

The EMO did away with that by building district-wide discount calculations.  The definition of "entity" no longer matters for determining discounts.  (OK, it still does for consortia, but I hate consortia, so I'm ignoring them.)

But then the FCC perversely made the $150-in-5 budgets building-specific.  Aside from being a nightmare to keep track of (the need to track this budget for each location (and then contribute some of the budget to a piece of equipment at another location if that equipment will serve the location in question) has really increased the demand for my services as applicants finally throw up their hands), the budget now makes it important what an "entity" is.

Here's a real-world example.  A high school with 1500 students sits across the parking lot from a pre-school with 200 children.  If they're two separate entities, then the high school gets $225,000 and the pre-school gets $30,000.  But that pre-school doesn't need any new network gear, since no one is letting 4-year-olds roam the Internet, and pre-K teachers are interacting with children, not smartboards.  A couple of hand-me-down 802.11g APs is enough for the teacher's iPads.  So if they are separate entities, that $30,000 goes largely unused.  The high school, meanwhile, needs a wired network and two wireless networks (one for school devices, one for BYOD), and those kids are going to want 802.11ac speeds, so $225,000 is nowhere near enough.

The district will be tempted to make "entity" mean "campus" instead of "building," so they can have an extra $30,000 to spend on the high school.

If you're going to hand out money on a per-entity basis, shouldn't you say what an "entity" is?

Friday, February 06, 2015


I started reading Commissioner Rosenworcel's speech at the Texas Computer Education Association, and my first interrobang was "Nintendo 64?!"  It seems wrong for a couple of reasons.

First, OK, it came out in 1996, but it wasn't even released in Japan when the Telecommunications Act of 1996 was passed.  It was only available in the U.S. in September 1996.  So to say "in 1996, a device meant a Nintendo 64" seems misleading.  For most of the year, it meant Nintendo SNES or GameBoy.  Or PlayStation.

But what does a game system have to do with the E-Rate?  OK, the Nintendo 64 was a device, but not a device capable of connecting to the Internet.  I think Nintendo didn't have an Internet-capable device until the DS in 2004.

What, you thought I was going to provide some real information?  Well, OK, check this out.

I'm fine with the Commissioner's call for the Lifeline program to support home broadband.  But I recently read an interesting study on what Commissioner Rosenworcel calls "the Homework Gap."  The conclusion: "...the introduction of home computer technology is associated with modest but statistically significant and persistent negative impacts on student math and reading test scores. Further evidence suggests that providing universal access to home computers and high‐speed internet access would broaden, rather than narrow, math and reading achievement gaps."

I did not see that coming.

Sunday, February 01, 2015

Biggering broadband and the USF

A couple of changes by the FCC seem likely to affect our beloved E-Rate, so I thought I'd mention them to those who don't waste their time reading FCC news items.

First, the FCC has changed the definition of broadband.  I missed the announcement in 2010, when the FCC changed the minimum speed to qualify as "broadband" from 200 kbps to 4 Mbps. Boy, they sure took their time to increase the standard from a couple of ISDN BRIs to a few bonded T-1s.  Now they're moving from 4 Mbps to 25 Mbps.

How will that affect the program? Well, the E-Rate Modernization Order was all about focusing on broadband (the word "broadband" is used 283 times in the Order).  Now while the FCC seems reluctant to toss technologies that can't meet the broadband threshold (the Eligible Services List included some transmission technologies that couldn't reach even the old 4 Mbps threshold, like ISDN and fractional T-1s), maybe at some point maybe someone will notice that several items on the ESL don't provide broadband, and slow connection speeds will be tossed out of the program.  Of course, the E-Rate goal is 100 Mbps, so maybe this move to a 25 Mbps minimum won't really matter.  But at some point, someone's going to point out that T-1 lines, even with bonding, cannot meet the new broadband standard (and they cost over $200 per Mbps), so they shouldn't be on the ESL.  I mean, if you want applicants to move to 100 Mbps, it makes sense to stop subsidizing 1.5 Mbps connections.  If the focus is broadband, let's stop funding things that aren't broadband.

Second, the Chairman seems poised to make Internet subject to Title II regulations as a way to enforce Net Neutrality.  (Which has his former employers at the NCTA most unhappy.)

Why should we care over here in the E-Rate program?  Well, according to Commissioner Pai, "Once broadband service is classified as a telecommunications service, universal service charges will be assessed on carriers’ broadband revenues."  So it looks like as an ?unintended? consequence of Net Neutrality, ISPs will have to start kicking into the USF.  Maybe that's where the extra $1.5 billion for the E-Rate program will come from.

And since I haven't gotten to play language curmedgeon for a while:
Hey, Commissioner Pai, "broadband" is not synonymous with "Internet."  Carriers already pay USF fees on broadband circuits that are used for WANs.  The change would be in the cost of Internet access (whether broadband or not).

I've already ranted about "broadband" not really being the same as "high-speed," but I guess I have to give that one up: the original meaning of broadband seems to be lost.