Duplicativicity

Early reports indicate that USAC has misunderstood what they asked for on the Item 21 Attachments, and PIA is going to be asking about "duplicative services" over and over.

See, if your ISP provided the circuit from your district hub to the ISP's POP, you were expected to describe that as "Internet and Transport" instead of "Internet only."  (I believe the thinking was that the information could then be used to better compare Internet pricing if you knew whether it was just the Internet port or port+circuit.)  Of course, then you'd also have a WAN providing Transport from the district hub to the other locations in the district.  So now you have Transport twice for each of the non-hub locations, so it looks duplicative.

And PIA is going to ask about it.  It's not duplicative, of course, which I hope PIA will understand quickly, but it creates a lot of extra work.

Meanwhile, you can't really draw any conclusions about the price of an "Internet and Transport" FRN, because you're allowed to dump your WAN (a telecommunications service) into an Internet Access FRN (a kludge that was created to allow statewide/regional networks and ESAs, which are not telecom providers, to provide WAN connections to individual schools).

Ironically, the warning that duplicative services are not eligible was removed from the 2015 Eligible Services List because the FCC wanted to "streamline" the ESL.  The FCC apparently feels that if you wanted to get $3,000 in funding for your school, it is your responsibility to find, read and retain the information in paragraphs 22-24 of the Second Report & Order (written in 2003).

In short, now that the duplicative services rule is well hidden, PIA is going to try to enforce it using misinformation from a system which had to be weirdly designed to allow grey-market sales of telecommunications services by states, ESAs, et al.