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Monday, June 20, 2016

Hope you like spam

I was looking at the new tool for downloading 471 info, and of course I have nothing but complaints.

  1. No ability to filter results.  Download the whole state, or download nothing.  That's a step backwards in functionality.
  2. No ability to select fields.  Another step backwards.
  3. Excel?  Really?  Getting our tools to step into various tabs of an Excel workbook is just a joy.
  4. It's bad enough that the file contains the email address for the Contact Person, but even worse, the Authorizer's email is in there.  Before last year, you couldn't even get the Authorizer's email by looking at a form.  And the Authorizer's title is in the file.  Now anyone can download thousands of email addresses.  And since EPC uses your email address as your account name, and doesn't allow alternate email addresses in the forms, those email addresses are going to be the real email address of those administrators.  Look for an increase in spammers and hackers coming to your inbox soon.  (Consultants' email addresses are also exposed now, but at least one commissioner will be happy to see consultants suffer.)
EPC continues to underwhelm.

Thursday, June 16, 2016

Полный стол

And now the press release is out, so here's the history table updated:
FY Window close Days passed PIA approved Days passed First FCDL Total days Millions Appli-cations $/app
2016 5/26/2016 14 6/9/2016 7 6/16/2016 21 $18 2,251 $7,996
2015 4/16/2015 -27 3/20/2015 62 5/21/2015 35 $151 7,100 $21,268
2014 3/26/2014 -19 3/7/2014 69 5/15/2014 50 $607 14,600 $41,575
2013 3/14/2013 57 5/10/2013 19 5/29/2013 76 $130 12,023 $10,813
2012 3/20/2012 35 4/24/2012 77 7/10/2012 112 $646 23,800 $27,143
2011 3/24/2011 75 6/7/2011 19 6/26/2011 94 $398 18,500 $21,514
2010 2/11/2010 91 5/13/2010 13 5/26/2010 104 $429 18,200 $23,571
2009 2/12/2009 49 4/2/2009 26 4/28/2009 75 $134 6,931 $19,333
2008 2/7/2008 63 4/10/2008 21 5/1/2008 84 $352 10,000 $35,200
2007 2/8/2007 4/23/2007 74 $202 21,000 $9,619
2006 2/16/2006 4/26/2006 69 $184 4,880 $37,705
2005 2/17/2005 6/27/2005 130 $342 7,700 $44,416
2004 2/4/2004 4/27/2004 83 $43
2003 1/16/2003 5/1/2003 105 $230
2002 1/17/2002 4/24/2002 97 $233 9,300 $25,054
2001 1/18/2001 7/23/2001 186 $478
2000 1/19/2000 4/14/2000 86 $253 13,000 $19,462
1999 3/11/1999 7/13/1999 124 $116 6,000 $19,333
1998 11/23/1998 $73 3,000 $24,333

By far the tiniest wave ever, both in dollars and number of applications.  And yes, it was mostly small applications: the last column shows the average total funding requested per application.  Much smaller than normal, but it looks like 2013 and 2007 were at least in the same ballpark.

Serious jacking on this wave

The first wave of FCDLs came out at 2:08 am today.  Huzzah!  And I learned about it in a series of emails.  Whooppee!

This wave certainly broke records for speed.  Only 3 weeks after the window close and one week after the FCC approved the secret PIA procedures, we have funding!  You can see below how that compares with past years.

How big was the wave?  I don't see a way to find the amount of dollars or number of applications approved.  The Search of Commitments and the Data Retrieval Tool don't have an option for 2016 funding.  I guess I'll have to wait for the press release.

Based on my own small sample, it seems that, as I predicted in 2007, once the filing window deadline was moved to May, Parkinson's Law reduced the amount of review done on small applications.  I mean really, when was it ever cost-effective to dig into a $109 monthly phone bill to see if it included an ineligible charge for $2.38?

(Some will say that the reduced need for review was due to changes in the Form 471 that gave PIA more of the info they needed.  I don't buy that.)

Life simplified for many applicants, and no real opportunity for waste, fraud or abuse.  Let's close the window in May every year.

Here's the history table updated:
FYWindow closeDays passedPIA approvedDays passedFirst FCDLTotal daysMillionsApplications
20165/26/2016146/9/201676/16/201621??
20154/16/2015-273/20/2015625/21/201535$1517,100
20143/26/2014-193/7/2014695/15/201450$60714,600
20133/14/2013575/10/2013195/29/201376$13012,023
20123/20/2012354/24/2012777/10/2012112$64623,800
20113/24/2011756/7/2011196/26/201194$39818,500
20102/11/2010915/13/2010135/26/2010104$42918,200
20092/12/2009494/2/2009264/28/200975$1346,931
20082/7/2008634/10/2008215/1/200884$35210,000
20072/8/20074/23/200774$20221,000
20062/16/20064/26/200669$1844,880
20052/17/20056/27/2005130$3427,700
20042/4/20044/27/200483$43
20031/16/20035/1/2003105$230
20021/17/20024/24/200297$2339,300
20011/18/20017/23/2001186$478
20001/19/20004/14/200086$25313,000
19993/11/19997/13/1999124$1166,000
199811/23/1998$733,000
I guess I'll have to post it again after we learn the amount of dollars or number of applications approved.

Thursday, June 09, 2016

Last hurdle cleared?

Today the FCC approved the PIA application processing procedures.  For those of you unfamiliar with what that means, every year, USAC sends the FCC a secret document describing the procedures they will use to review applications.  (That used to be a 700-page tome, but I wonder if it's larger or smaller than last year with the new EPC system.)  The FCC has determined that the procedures for routine processing of funding applications is actually a law-enforcement activity, and thus exempt from Freedom of Information Act requirements.  So we have the ironic situation of the FCC publicly approving rules that are kept secret.

Now that the Form 486 is available on EPC, and PIA processing rules have been approved, we could see the first wave of funding approvals at any time.  I'm betting on Tuesday, June 14th, but that's a total guess.  In the past, it has never been less than 13 days between the approval of PIA procedures and release of the first funding wave, but this could definitely be the year that the record falls.  It definitely seems like we'll be setting a new record for the fewest days between the close of the window and the date of the first FCDL.

Here's a table of dates from past years:
FY Window close Days passed PIA approved Days passed First FCDL Total days Millions Applications
2016 5/26/2016 14 6/9/2016
2015 4/16/2015 -27 3/20/2015 62 5/21/2015 35 $151 7,100
2014 3/26/2014 -19 3/7/2014 69 5/15/2014 50 $607 14,600
2013 3/14/2013 57 5/10/2013 19 5/29/2013 76 $130 12,023
2012 3/20/2012 35 4/24/2012 77 7/10/2012 112 $646 23,800
2011 3/24/2011 75 6/7/2011 19 6/26/2011 94 $398 18,500
2010 2/11/2010 91 5/13/2010 13 5/26/2010 104 $429 18,200
2009 2/12/2009 49 4/2/2009 26 4/28/2009 75 $134 6,931
2008 2/7/2008 63 4/10/2008 21 5/1/2008 84 $352 10,000
2007 2/8/2007 4/23/2007 74 $202 21,000
2006 2/16/2006 4/26/2006 69 $184 4,880
2005 2/17/2005 6/27/2005 130 $342 7,700
2004 2/4/2004 4/27/2004 83 $43
2003 1/16/2003 5/1/2003 105 $230
2002 1/17/2002 4/24/2002 97 $233 9,300
2001 1/18/2001 7/23/2001 186 $478
2000 1/19/2000 4/14/2000 86 $253 13,000
1999 3/11/1999 7/13/1999 124 $116 6,000
1998 11/23/1998 $73 3,000
I'll update that in a post after the first wave comes out.

Wednesday, June 08, 2016

An inconvenient truth

Am I missing something?  Or is everybody else missing something?

Yesterday, USAC sent the FCC the Demand Estimate for FY2016 (well, since the window for consortia and libraries isn't closed yet, it feels more like a Demand Estimate estimate).  Today, the FCC authorized the funding of all Category 1 and Category 2 funding requests.  That notice also authorized a $1.9 billion rollover.

First, the obvious good news:
  1. All C1 and C2 funding requests will be approved.
  2. Fast action by USAC and the FCC means that we could see C2 funding approvals as early as this month.
Now onto what no one else seems to have noticed.  No one noticed it last year, either.

It has to do with what people think the filing window, and what it really is.

People think that the filing window is the period in which you're allowed to file a Form 471.  File after the deadline, and your application is automatically denied.  And it has been true that if you missed the deadline, you didn't get funded.

But that's not really what the filing window actually is.  What is it?  Let's go to the rules, in this case 47 C.F.R. §54.507(c):
Requests. The Administrator shall implement an initial filing period that treats all schools and libraries filing an application within that period as if their applications were simultaneously received. The initial filing period shall begin and conclude on dates to be determined by the Administrator with the approval of the Chief of the Wireline Competition Bureau. The Administrator shall maintain on the Administrator's Web site a running tally of the funds already committed for the existing funding year. The Administrator may implement such additional filing periods as it deems necessary.
The close of the filing window is not an application deadline.  It just means that your application will not be considered as having been filed first, at exactly the same moment as everybody else who filed in the window.

Originally, the E-Rate was set up as a first-come, first-served program; USAC was supposed to fund requests as they came in, until they hit the funding cap.  But the FCC didn't think is was prudent to have applicants rushing to get their applications in, so in the early days of the program, the Third Report and Order established the filing window, and said that any applications filed in the window would be considered simultaneously filed.

Since funding requests were always over the cap, the effect was that if you didn't file in the window, you didn't get funded, because the funding ran out before it funded all the requests filed in the window.

The close of the filing window has effectively been an application deadline for all those years, but it is not actually a deadline.

Then last year, it happened: the fund didn't run out of money.  And this year, it's happened again.  For FY2016, the cap is $3.939 billion, and USAC estimates we'll have $1.9 billion in rollover.  So USAC is allowed to commit up to $5.839 billion.  The estimated demand is $3.609 billion.  So we have waaay more money than we need to fund all the applications filed in the window.

So what should happen?  The Third Report and Order envisioned the possibility of multiple windows, but there's no need.  USAC should just keep accepting applications until the funding runs out.  So if a district gets a grant in October to purchase a new wireless infrastructure, let them go through the 470 and 471 process then, and if there is still funding left, fund that district's request at that point.  That's the way the program was originally envisioned, and that's what the rules say.

Or am I missing something?