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.