Search This Blog

Thursday, December 22, 2016


Wow, now here's a bad idea.  You can only contact USAC's Ombudsman through the Client Service Bureau.  Try emailing the ombudsman, and you get an auto-reply telling you to contact CSB (in the E-Rate, even customer service hides behind an acronym). Is this part of the new "Customer Engagement"?

I shouldn't complain, because it's good news for E-Rate consultants.  What will an applicant do when they get a response from CSB that is a quote from some SLD Web page that doesn't answer their question, but has whatever keyword the CSB rep searched for in trying to find an answer?  The Ombudman was created to help applicants who were getting stymied by CSB (or other contacts with USAC).  Now if you can't get a straight answer from the CSB (who, I believe, work in Lawrence, KS for Vangent, a division of General Dynamics, which is contracted by Solix, which is contracted by USAC, unless one of those contracts has changed), you can contact...the CSB.  And if that doesn't work, you can go to...the CSB.  After a couple of rounds of getting unhelpful quotes from SLD Web pages, applicants will have no choice but to ask a consultant (or maybe a state E-Rate coordinator, though back in 2009, the GAO said that 79% of applicants found consultants are very or extremely helpful, while only 67% said state coordinators were).

Speaking for myself, the disappearance of the Ombudsman just means that instead of contacting that office, I'll go straight to whichever USAC employee has the info I need.  As an E-Rate professional, I know who does what inside USAC, and usually I have met the people involved.  I was only using the Ombudsman to be respectful of other USAC staff's time.  (I apologize in advance to all the folks at USAC who will be hearing from me more often.)  But a regular applicant has not had the good fortune to interact with the lovely people at USAC (that's meant to be unctuous, not sarcastic; they really are nice people), so the applicant is stuck.  I guess they'll contact Craig Davis directly, or try to write to the USAC Board.

Can we start a petition to save the Ombudsman?

Thursday, December 15, 2016

And so the Wheeler turns...

Well, it's official, Chairman Wheeler resigned effective January 20, 2017, the day President Trump is inaugurated.With the Senate not confirming Commissioner Rosenworcel before recess, she's gone, too.

So we're down to 2 Republicans and 1 Democrat.  The new prez will nominate 2 more commissioners, a Republican and a Democrat.  Well, actually, the rule is that the commission can't have more than 3 commissioners from any party, so maybe he could nominate a Republican and someone who doesn't belong to either party.  Normally that would be out of the question, but with this President....

Then the Senate has to approve the nominees.  The tradition has been that both nominees would be confirmed at the same time, but we may see that convention go by the wayside.  Will the Democrat get the Garland treatment?  Or will the President dilly-dally on nominating the non-Republican?

And what does it mean for the E-Rate?  Well, Commissioner Pai said, "We need to fire up the weed whacker...."  But it sounds like he's really gunning for Net Neutrality, municipal broadband and the like.  And a while a weed whacker sounds painful, we managed to survive Chairman Wheeler's "Strike Force."  And it's not guaranteed that Pai will become Chairman.  I suppose on January 21 Pai will be in charge at least until the other commissioners are appointed, but I don't know what he'll be able to do in the interregnum.

Commissioner Pai did float a proposal to dramatically simplify the program.  What should he focus on first?  Dump the 470!  If the program is simplified, that might be bad for consultants.  But I have faith in our government: every time the FCC "simplifies" the program, it confuses people and drives them into the arms of consultants.

Farewell, Chairman Wheeler.  You were a much better chairman that I expected.  And you've got to like someone who can laugh when he gets called a dingo.

Tuesday, December 06, 2016

Campus? More like Krampus.

Back when I live-blogged training, I pointed out the muddled misery caused by campus vs. location vs. school vs. entity.  Now the latest News Brief brings some additional information, which, as usual, means additional pain and confusion for applicants.

First, the definition of "campus" just got even muddier.  It used to be the only thing that split a campus was a public right-of-way.  Now any road (not necessarily public) or stream can split a campus.  What?!  Now I have to walk my clients' campuses looking for streams to see if I need to create annexes because there are different campuses?  Do gulches that only have water sometimes count as streams?  We can assume that if streams split campuses, rivers certainly would, but what about brooks or rills?  What if a stream runs between two buildings, but only partially crosses the campus?  What if a road crosses a stream? Can a stream/road combo create a separate campus?  Suddenly, I feel like I'm playing the latest expansion pack of Carcassonne.

Hey, our local primary school was built on wetlands (I know you can't believe it, but it's true).  Do wetlands count as part of a stream for purposes of determining campusity?

What is a "road" that's not a public right-of-way?  A driveway?  I can't find a good definition of "road" anywhere.  And the legal treatment of vehicular pathways seems to vary quite a bit from state to state.  How can I learn the legal status of the driveways on my campus to try to figure out if they meet the (non-existent) definition of "road"?

Now that I don't know whether I have one campus or several, let's use that non-definition to determine whether a service is C1 or C2.  Buckle up!

The first example looks easy: if you have one school on one campus, all connections are C2, even if you have multiple buildings on that campus.  OK, but what if Google Maps shows the vehicular pathways on my campus as roads?  Does that make them roads?  If the town maintenance department has to use that pathway to get to it's salt storage building, does that make it a road?  What if the driveway is shared by two schools?

How did they write the second example without mentioning the word "annex"?  That's what we're talking about, right?  What else would a separate location of a single school be called?  [Or will annexes go extinct when EPC hits the trash heap next year?  Oh, goody, we can make all those annexes back into entities (well, annexes are listed under "Related Entities," so I guess an annex is an entity, but you know, I mean "entity" as in "location with a Billed Entity Number," not "entity" as in "thingy in the EPC database, whether or not is has a BEN").]

And their example is ridiculous.  Choosing two campuses separated by a major thoroughfare was facile; how about using a campus with a stream through it as your example?  But then the unrealism kicks in: "The middle school has administratively defined the grounds on one side of the thoroughfare as 'Campus A' and the separate and distinct grounds on the other side as 'Campus B.'"  What?  "Administratively defined"?  What does that mean?  They call the two buildings by 2 different names?  Different mailing addresses? What if my lovely campus has a stream running between two buildings, but we've never identified them as separate campuses?  Are they still separate campuses?  When this hits the real world, no one will now what to do.

But the third example takes us from the muddy to the absurd.  Three schools in one building are 3 campuses, and connections between those schools are C1.  Oh, my aching head.  Let's just take an unrealistically simple example where each school has an MDF, and all horizontal runs stay inside school boundaries.  Now if I want to connect those 3 MDFs with fiber runs, those connections count as self-provisioned fiber.  Which means that I need to convince someone to give me a bid on a leased dark fiber and on some kind of lit fiber service inside my building, so that I can demonstrate that self-provisioned is more cost-effective than the other options.  What service provider is going to prepare that bid, knowing they can't beat the self-provisioned cost?  And what if the cable company does come in and proposes cable modems in every MDF VPNed together?  Dang, that's going to be pretty cheap.  Do I really have to put my LAN backbone on a VPN? I guess we have to put latency specs in our RFPs, which is beyond the expertise of your average school tech person.  So now the district has to hire a fiber engineer to do a design for a leased fiber infrastructure which is not going to be built under any circumstances.

And that's all in USAC's unrealistically clean example.  Let's take a pessimistic, but not unrealistic example.  Let's say you have a building that's basically just a 400-foot-long hallway with classrooms off each side (the hallway doesn't have to be straight; I can think of several schools that have U-shaped or O-shaped hallways that long).  It's a 3-story building, and you're going to put 3 schools in there, so naturally you put a school on each floor.  Because of that hallway length, you can't serve a whole floor with a single closet, but a clever network designer would realize that if you put in one closet on each side of the 2nd floor, each closet would be able to serve all 3 floors for half the building.  So what now?  Is each individual cable run to the first and third floors a C1 connection?  What does that make those runs, self-provisioned copper?  Is that eligible?  Do I still have to compare the cost of each run to a leased dark fiber and lit fiber connection between my classroom and the wiring closet?  Can I compare it to the cost of leased dark copper and lit copper?  (I know, no one offers that service, but no one offers lit fiber inside your own building, either.)   If I've got 4 runs to one classroom, do I have to get a bid for 4 leased pairs and a bid for 4 lit fiber connections?

And if all 3 schools share a cafeteria, and you put an access point in there, now I have to share the cost of that run and that switch port among the C2 budgets of all 3 schools.  And what if only 2 of the schools in that building share an art room?  As long as the drops in that classroom go back to a closet located in one of those 2 schools, I guess I just cost-allocate it between those 2 schools?

And then one of the schools closes, and a new school opens in that space.  (You would think that's very unusual, but some districts have figured out that if they create academies, when that academy fails to meet NCLB requirements for 3 years, they can just close that academy and open a new one, and they have a clean slate.  It looks like a district trying innovative new ideas, but it's just a shell game.)  Does the new school have to rebid the cable runs to its location?  What if that was the school on the second floor?  Do the other schools have to rebid their C1 connections to the second floor, since there's a new entity there?

OK, now I've gotten to extreme (but not unrealistic) cases. Most shared buildings will be somewhere in between.  Some closets will serve only one school, but most closets will serve classrooms in multiple schools.  So most closets will have both C1 and C2 connections.  Now the switches are going to have both C1 and C2 connections going into them, so you'll have to cost-allocate the cost of switches across categories?  There's a brand-new headache.

And then at some point the administration is going to decide to swap rooms between that ungraded special ed classroom (which has students from more than one school,so it's shared, so it's C2) and the 4th-grade classroom next door (which had been served by a closet in the Middle School sharing the building, so it was a C1 connection).  So the C2 connection becomes a C1 connection and vice versa.  Do I have to get leased dark fiber and lit fibers bids and compare them to the wire that's already there?  I can't even imagine what I'm supposed to do about a connection that was C1 and becomes C2.

And what about offices?  If the Superintendent's office is on that campus, what am I supposed to do about those connections?  Is an office that serves all schools in the building treated like a shared classroom?

You know what might simplify your life?  Find a shared room like the cafeteria, and put a fiber switch up on the wall.  Then have all your wiring closets connect to the cafeteria.  Since it's a shared room, all connections to it are C2.  And you'd have some great viral videos of the tech director with a lacrosse goalie stick trying to protect that switch during food fights.

Wait, who decides what is a "shared classroom"?  Can the schools just declare all wiring closets to be shared classrooms?  Then all the connections in the building are C2, regardless of which school they connect to.  Just don't look too closely, because the cost-allocation tangle could be extremely messy.

Excuse me, I need to find some aspirin, since it's too early to start drinking.

Monday, December 05, 2016


As 470 season heats up and the 471 window approaches, and yet no dark fiber requests from last year have been approved, here is a device we all need:
RESPeRATE Blood Pressure Lowering Device

[Of course, I'd prefer Resp-E-Rate, and I feel compelled to point out that the correct spelling is "respirate," but hey, at least the second R is capitalized.]

Thank you, Google.  How did you know?