On-premise Category One circuits

15 minutes for the Eligible Services List?  Oh, dear.  Well, since the ESL is so brief now, we got through it in about that time.  But then came the questions.

The thorny questions were all about the new definition of "entity" (as in location/campus, not "entity" as in organization).  What we heard was that if you have a single building which the state DOE considers, say, a middle school and a high school, they are two entities, and any connection between those entities is Category One.  On the flip side, if an annex is across the street from its parent entity, that connection is Category Two.  Among the questions this brings up:

1. If we have to apply under Category One for the fiber between the middle school IDFs and the high school MDF, what are those connections?  A self-provisioned network?  Meaning we also have to request bids for leased dark fiber inside the building?  Would the core switch then be partially C1, since it is lighting up fibers to the middle school IDFs, which are now C1?
2. What if we have a pre-existing Category One contract for the WAN between a school and its annex?  Do we have to rebid that as a C2 service?  If it's leased lit fiber, how do we recast that as C2?
3. What about a building that has 3 different schools in it, but the schools share the classrooms?
4. What about our middle school/high school building if the IDF is sitting in the middle school, but has 4 cable runs to a high school classroom.  Are those 4 cable runs now C1?

And what answer did we get?  "Those are good questions."

New VP

As you might expect, my reporting from the USAC training will involve me taking tidbits out of context and giving my opinions.

I was able to drag myself down for the Beginners session, and I learned something!  Mackenzie said that the target length for the filing window is around 75 days.  I had certainly noticed that the window is usually around 75 days, but this is the first time I've ever heard that it's an actual target.

I thought Craig Davis, new head of the E-Rate program for USAC ("Vice President, Schools & Libraries Program"), struck a nice balance of positivity and realism.

Mr. Davis said that USAC will shortly hire a new Director of Stakeholder Engagement.  I guess it's not news, since the job listing was posted 7 months ago, but it's news to me.  I'm all for more stakeholder engagement, but reading the job description, the "Your Role" section mentions "understand the challenges our stakeholders face", but under "Responsibilities," it's all about pushing information out to stakeholders.  There is no mention of listening to stakeholders.  I guess I was hoping "engagement" would involve information flowing both ways.  But after looking at the background of the USAC-wide VP of Stakeholder engagement, I can see that "engagement" is what those of us without MBAs would call "marketing."  Oh, well.

Mr. Davis also mentioned that he wanted to "de-leverage your risk" in applying for the E-Rate.  That sounds good.  Since I'm not investing in E-Rate, I'm not clear on what my risk is, or how I'm leveraged, but I'm hoping it means "reduce the risk of funding denial."  I think USAC and the FCC moved a long way in that direction in the 3 years after Bishop Perry, but I'm hoping this means we'll see more movement in that direction.

Come on, baby, light my fiber

I'm trying to stay relaxed this year, just rolling with the weirdness, and I made it until the Broadband Fiber Options presentation before I started grinding my teeth.

First, the little gripes.  We learned that if you say "self-provisioned network" on the Form 470, and describe it as "dark fiber" in your RFP, that will create difficulties in getting through PIA.  I have three problems with that:

1. Self-provisioned fiber is dark fiber.  Only at USAC does "dark fiber" mean a leased service.  In the rest of the world, any fiber that is not lit by the service provider is "dark fiber."  In fact, if you say to a service provider that you want to build a dark fiber network, they will think you want what USAC calls a "self-provisioned network."
2. How is an applicant supposed to know that "dark fiber" means "leased dark fiber"?  In the ESL, it's always "leased dark fiber," not just "dark fiber."
3. Number one question I get from potential bidders: "What does 'self-provisioned' mean?"  I've never heard anyone outside the E-Rate program use that term.  

So if applicants only use the term "self-provisioned network," service providers that have not spent much time on the E-Rate program will think that the applicant is looking for some kind of deal where the applicant buys the cable and the service provider puts it on the poles.  And if you don't say it's dark, the service provider will want to know if they're expected to light the fiber.

I understand the need for jargon, but if you take a term that has an actual meaning ("dark fiber" or "RFP") and use them to mean something else ("leased dark fiber contract" and "specifications or any other information beyond what's on this 470"), it creates confusion.  And when you appropriate a commonly-used term as jargon, it makes it very difficult to clear up what your jargon means. 

But the real teeth-grinding started when we got into the requirement that leased dark fiber must be lit before the end of the funding year.  I heard in the hallway that fiber FRNs haven't been approved yet.  If they got approved today, those applicants would have 9 months to do all the engineering, permitting, make-ready, installation and testing.  For small, simple projects, that might be enough time.  For large, complex projects, it just isn't enough time.  And if you don't get approved until February, you only have 4 months to get all that done.  The FCC did say that if you got an FCDL after March 1 of the funding year, you could file an appeal saying that you should get another year to light the fiber, and the FCC might grant that appeal.  Two problems: 1) "might"; really, you think someone should be able to install a self-provisioned network in a couple of months? and 2) there is no precedent on this, so there will be no quickie appeal decision, which means the response time on your appeal will be measured in months and years.

And what problem is solved with this weird restriction?  Does the FCC really think that there is an applicant out there thinking, "Hey, let's build a self-provisioned network this year in case we need it in a couple of years," or "Hey, let's lease a fiber pair this year because we're going to need it in 3 years."

A terrible restriction to prevent a non-existent problem.

New Face

A little liveblogging from the USAC training in DC.

So far, the biggest news comes from the cover of the handout folio:

Where's the yellow swoosh?  Is the logo changing?  Or is USAC just saving some money by printing in one color? (Although it looks like there are four different blues, which makes me think they couldn't get the one-color savings.)


Other important news: Don't count on USAC to provide your breakfast.  There was a meager table, quickly cleared away.  Plenty of caffeine, though.

Lots of new faces in the opening remarks.  They're saying all the right things, too.

Yukon Ho!

I was poking around the Search Commitments tool, and I thought, "I wonder what's the biggest FRN committed so far?"  $27 million in E-Rate funding!  "Wow," I thought, "can even NYC get that high with the $150/student cap on Category 2?"  So I looked over at the applicant name.  "Lower Kuskokwim? This must be a typo.  Wait, is that in Alaska?"  Yup.  That district of 4,025 students spends over $30 million on Internet and WAN each year.  Well, the E-Rate spends $27 million and they spend $3 million.  That's a pre-discount cost of $7,668.73 per student.  Every year.  Wow.  Kind of puts that $150/student Category 2 budget in a different perspective, doesn't it?

How could data transmission possibly cost so much?  Just look at the map of the schools.  Some of those schools are over 100 miles from the district office.  At 26,253.5 square miles in area, it's the 8th-largest district in Alaska (and the 8th-largest in the U.S., since the 14 largest districts are all in Alaska).  Microwave towers can only be like 30 miles apart, right?  And I don't think anyone's stringing fiber across the Yukon Delta National Wildlife Refuge.  Here's a map showing how it's done.

Getting back to my first thought: with around 1 million students, the NYCDOE can get an average of around $30 million in C2 funding every year (though they could take it in one $150 million pile if they wanted).