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Wednesday, March 11, 2015


The Council of the Great City Schools (CSGS) request for an extension of the filing window has me in a ranting mood.

The first reason that CGCS gave for needing an extension is an explosion in the complexity of the 471.  What caused the explosion?  The need to cost-allocate Category 2 purchases among locations.  The reason cost allocation is necessary?  Because the FCC made the $150-in-5 budgets location-specific.

Can we get that rule changed?  We should have a district-wide Category 2 budget.

First, per-location budgets solve a problem that doesn't exist.  Does the FCC really believe that a district is going to look at two of its elementary schools and for some capricious reason spend more on one school than the other?

Second, it restricts a district's flexibility in trying to meet its actual needs.  Districts should spend more on technology for some schools than others.  For example, districts should spend more on Wi-Fi for high schools than for pre-schools, because high school students have 2 or more Internet-connected devices with them at school (it's no longer "BYOD or 1-to-1"; it's both), while the pre-school kids have zero Internet-connected devices.  The high school needs more than $150/student.  The pre-school needs less.  But thanks to the FCC's perverse rule, the high school students will be in the Bandwidth Hunger Games, while the pre-schoolers will be bathed in bandwidth they can't use.

Here's an extreme example, but it is actually happening this year.  A district has 3 schools: 2 elementary and 1 high school.  Last year, the roof of one of the elementary schools gave out, which completely destroyed the data network.  The district ponied up its own money to put in an entirely new network at that school.  (There is no way to get E-Rate funding in time to cover a catastrophe, and besides, the FCC hasn't chosen to fund Priority 2 for the past couple of years.)  They don't plan to spend another dime on that school in the next 5 years.  But because their budget is location-specific, what are they going to do with the $150/student budget for that school?  They're going to tear out all the new switches and access points in that elementary school and move them to the high school, then buy the same equipment with E-Rate funding and replace the equipment they just removed from the elementary school.  That school has zero need for E-Rate funding, but because the FCC forces them to fund that location, they are going to ridiculous lengths to artificially create a need.

Third, it creates complexity.  The CGCS letter says that one Chicago Public Schools 471 will have 17,500 line items because it has to allocate costs among 250 schools.  (It would have been 35,000 line items if they'd included all 500 of their schools on the 471.)  How many person-hours will be wasted by Chicago creating that monstrosity, and how many will be wasted by USAC reviewing it?  LAUSD says that it's going to take them 5-7 days per application, as opposed to the 1 day it took to do before the per-location budgets.  5 times the work.

Fourth, it creates more complexity.  If the $150-in-5 budget weren't location-specific, there would no longer be any need to track the location of equipment.  Until this year, USAC had to track locations and the FCC had to make up a rule about transferring equipment so that districts wouldn't use high-discount locations as "equipment mills," buying new equipment every year (or twice every five years after that rule came in) and then giving their old equipment (or excess new equipment) to other (lower-discount) schools in the district.  Thankfully, the FCC got rid of location-specific discount rates.  But by making budgets location-specific, the FCC made it necessary to continue to tie equipment to locations.  It creates a whole bureaucracy around equipment transfers.

Fifth, it creates even more complexity.  USAC had to create a special procedure for handling cost allocation of Basic Maintenance.  I can't find it online yet, but yesterday we got a News Brief titled "Guidance for the Online FCC Form 471 Alternative Data Entry Process for Basic Maintenance Funding Requests."  (It even coins a new E-Rate acronym: ADE.)   Yet another fork in the road as you try to find your way through the application process.

So to solve a non-existent problem, we get inflexibility, complexity, complexity and complexity.

On the plus side, this rule is dramatically driving up demand for E-Rate consultants.

And I'll slip in a little something from an unrelated rant.  Imagine the above post if I'd used "entity" instead of "district" and "location."  It would have been an incomprehensible muddle advocating entity-wide budgets instead of entity-specific budgets, asking that Category 2 budgets should be allocated on a per-entity basis, not a per-entity basis.  Let's get the word "entity" out of the program.

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