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Monday, November 13, 2017

Just sayin'

Ooh, look at item 4 on the agenda for this Thursday's FCC meeting: " Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment." 

Hey, here's my suggestion: stop the kafkaesque and ever-shifting review process for self-provisioned fiber.  Millions of dollars of broadband deployment has been held up by these wasteful reviews.

Tuesday, October 10, 2017

None shall pass

I'm sitting in USAC training at the moment, and I just heard EPC called a "portal."    Took me back to those rosy days when I dreamed of a portal that made my life easier.  After two years of toiling in EPC, the use of "portal" made me snort (really quietly).  "Portal"?  More like "portcullis."

Friday, June 30, 2017

Hey, where you going with that money?

The punches just keep coming.  In April, Chairman Pai let USAC have it. Last month, Commissioner O'Rielly said, "I believe that all options should be on the table, including putting USAC’s functions out for contract...."  In response to yesterday's GAO report that found problems with the Lifeline (née Low Income) Program of the USF, Commissioner O'Rielly said: "I have little the ability of USAC to stem the tide of problems. More significant reform is needed, including completely rethinking USAC.”  He sure has it in for USAC.

Of course, I only wanted to look at the summary of the GAO report (basically scanning for anything E-Rate-related).  Let's see: blah blah blah blah
"In March 2017, FCC developed a preliminary plan to move the USF to the Treasury."
[record scratch]

Say what now?!  Where is this plan?  To the full GAO report!

Page 23: "According to correspondence received from the FCC Chairman’s Senior Legal Counsel, as of March 2017, FCC has decided to move the funds to the Treasury....  FCC’s Office of the Managing Director prepared a preliminary project plan for moving the USF to the Treasury with the goal of completing the transfer in approximately 1 year."

Oh, crap!  As I said back in 2005, this is step one to killing the E-Rate.  Get it into the Treasury so that it will be easy to "so underfund it that it goes away."

Do you think I'm being paranoid?  OK, maybe, but that doesn't mean I'm wrong.  Back on page 23 of that GAO report:
"...FCC explained that having the funds in the Treasury could allow USF payments to be used to offset other federal debts...."

It seems to me they're saying that the USF could be used to pay down the national debt.  At this moment, the federal debt is $19.96 trillion, which means the $10 billion that USF collects annually is 0.056% of the debt.  The government is paying something like 0.8% interest on t-bills, so we'd need 15 times the total amount of the USF just to pay the interest on the debt.

This is bad.  When was the FCC going to tell us about this?

Is this a silver lining?
Page 24: " May 2017, while reviewing a draft of this report, a senior FCC official informed us that FCC experienced some challenges associated with moving the funds to the Treasury, such as coordinating across the various entities involved, which raised some questions as to when and perhaps whether the funds would be moved."

Stay tuned.

Meanwhile, back to the sidelong glance the FCC seems to be giving USAC.  Page 24: "beginning in November 2016, FCC sought to amend the contract between USAC and the bank to enable the bank to act on FCC instructions independent of USAC in the event USAC ceases to be the administrator."

Wednesday, June 14, 2017

She's baaaaack

I did not expect this: President Trump has renominated Jessica Rosenworcel to the FCC.

First, is it good news for the E-Rate? Yes!  Crucially, she has historically used the big "R" in "E-Rate."  She used to work for Senator Rockefeller, the godfather of the E-Rate, and she has been very supportive in the past.

But don't expect her to be approved instantly.  If she were, it would create a 2-2 tie on the Commission, so I'll bet that the Senate will sit on their hands until President Trump nominates a third Republican commissioner.

I also just have to show the timeline of Ms. Rosenworcel's nomination for a second term on the FCC:
Dec. 2014: Commissioner O'Rielly is confirmed; in return for Democratic agreement, Republicans promise to confirm her quickly when she's nominated for reappointment.
May 2015: President Obama nominates her for a second term.
July 2015: Her first term technically ends, but she's allowed to continue serving until December 2016.
Oct. 2015: The Senate Commerce Committee holds a hearing on her reappointment.
Dec. 2015: The Commerce Committee unanimously approves her reappointment, and passes it to the full Senate for confirmation (which is normally a formality).
Mar. 2016: At a Senate hearing, Chairman Wheeler is vague on whether he'll step down at the end of his term.
Apr. 2016: Democrats moan that Senator McConnell is delaying on the confirmation vote, in spite of the promise they made in 2014 to reconfirm her quickly.
Sept. 2016: Senator Thune suggests that her confirmation might be smoothed if Chairman Wheeler agrees to step down at the end of Obama's term.
Sept. 2016: Chairman Wheeler says he'll give up his post, but not when.
Nov. 2016: Two Democratic senators put a hold on her confimation.  Now that's a twist: Democrats holding up one of their own.
Nov. 2016: Three days later, the Democratic senators lift their hold.
Dec. 2016: Chairman Wheeler offers to step down if the Senate will confirm her.
Dec. 2016: The Senate adjourns without voting on her confirmation.
Jan. 2017: President Obama renominates her.
Mar. 2017: President Trump withdraws her nomination.
June 2017: President Trump nominates her.

Did you notice that of all the people in that timeline, there was only one "she"?  We still have a long way to go.

Friday, June 09, 2017

DDIY (don't do it yourself)

I didn't make it to the SHLB conference last week, but John Harrington from Funds for Learning was kind enough to publish the slide deck from his presentation.  As usual, I skipped to the pictures.  On page 10, we learn that in FY 2017, 16% fewer organizations applied for funding than in FY2014.

Why are applicants leaving the program?  I think there are 2 main reasons:

  1. Complexity is increasing.  In 2015, they changed the Form 471, which confused people who only filed one form a year, and in 2016, they introduced EPC, which made applying for funding much more difficult.
  2. Funding is decreasing.   For many small applicants, when voice is phased out, the remaining funding opportunity isn't worth the hassle.  And some libraries that don't filter were only getting voice funding, so they can't apply.
Which is worse, the increasing complexity or the decreasing funding?  Maybe we can get an idea from the graph on page 12.  It shows that the number of applicants not using consultants has dropped over 39% from FY 2014 to FY 2017, while the number of applicants using consultants has increased over 8%.  I think the only reason that consultants would be getting more clients while the total pool of applicants shrinks is the complexity of the program.

How can we fix this?  I already answered that.

Wednesday, May 10, 2017

What $150/student gets you these days

Is $150/student (or $153.47/student) enough to cover Category Two costs?  I think not.

Here's today's data point:
A client is building a new middle school.  That means they need everything.  What will their C2 budget cover?  Well, it's almost enough to cover access points (in the box, not installed) and cable (boxes of Cat6 cable, not pulling or terminating (in fact, not even terminating hardware)).  So no switches, routers, LAN controllers, licensing, etc.  To say nothing of the cost of installing or maintaining any of it.

The total of all eligible C2 costs for the building is closer to $500/student.

Friday, May 05, 2017

Wood shed? Firing squad?

Commissioner O'Rielly, who is now Chairman of the Federal-State Joint Board on Universal Service, has put USAC on notice!  Chris Henderson, the USAC CEO, resigned this week.  Usually, I'd expect to see some sort of "thank you for your service" from one of the Commissioners, but instead, Commissioner O'Rielly fired off this cannonade: "“The departure of its CEO presents an opportunity for the Universal Service Administrative Company (USAC) to clean up its act. ... Absent significant and timely improvements, I believe that all options should be on the table, including putting USAC’s functions out for contract...."

The tone is similar to Chairman Pai's recent missive to USAC, but Pai's letter just said, "You need to shape up!" whereas O'Rielly's says, "Shape up or ship out!"

Should the FCC actually consider firing USAC?  Well....

Long term?  Yes, they should at least consider it.  I find it ... um ... "interesting" that the company running this program is "a not-for-profit, independent, wholly-owned subsidiary of the National Exchange Carrier Association, Inc. (“NECA”)."   NECA is the lobbying firm for the telephone companies.  Even more "interesting," about a quarter of USAC's operating expenses are paid to Solix, a for-profit subsidiary of NECA.   That just doesn't smell dainty, although it would be hard to find an organization that was both competent to run the program and free of any industry ties.  Still, it would look nice if the FCC at least looked at other options.

Short term?  No.  In a time of turmoil for the program, we don't need a whole new organization running things.  There has been a lot of turnover at the top, but there is still a lot of institutional knowledge in the trenches.  This past year, I often find myself responding to USAC decisions with, "WTF?", but occasionally it's, "Now that's good thinking."  If USAC is replaced, there would be a lot more "WTF?"

Personally?  No.  In general, I like the people at USAC, and I want them to keep their jobs.

If the FCC does decide to replace USAC, I hope they'll make a careful search and have a nice, long period of transition.

Thursday, May 04, 2017

EPC fail-of-the-day

This is a fun one.

I don't know how often this happens, but sometimes when you're working on a 471 and you leave it for a while, when you come back and click on it in your Tasks list, you get:
Error message

You can't get back to that 471.  Ever.  You have to start a new one.  It's been dubbed the "Vanishing 471" trick.

But that bug is no fun on its own.  It just creates panic ("What did I do?  Where did it go? Was it submitted?") and more work.  To make it fun, we need to add in another bug.

There is another EPC "feature" that I call the "Midnight Save & Share" trick.  Occasionally, at midnight EPC selects a few incomplete 471s (no one has ever figured out the selection criteria) and basically presses the “Save & Share” button.  It's just as if the form's owner had clicked "Save & Share": the owner can no longer access the form, and it appears on the Tasks list of every other user with permissions for that form.

(Side rant: when I "Save & Share" a form, why can't I look at that form any more?  Really, it's more like "Save & Give Away.")

That bug isn't fun, either.  It just creates panic ("What did I do?  Where did it go? Was it submitted?") and more work.  But for those of us unfortunate to be habituated to these failures, the combination of those two tricks can create the fun.

Last night, a previously vanished 471 was selected by EPC for the Midnight Save & Share.  So now that 471 is on the Tasks list of all the users with permissions (except, of course, the creator), but if anyone clicks on that task, they get:

And that task vanishes from their Tasks list.  But don't worry, the task reappears the next time they go back to the Tasks list.  So I guess from now until the end of EPC, that task will be sitting there.

It's like an online fidget: I can go to my Tasks list and click on the task for that Vanished-then-Midnight-Save&Shared 471 and get a pink error dialog box, watch the task vanish from my list, then refresh the page and see the task reappear.

It would just be another amusing EPC quirk, except that it also appears on the Tasks list of my clients.  Which means a year from now, some infrequent EPC user in the district is going to call me in a panic about how they have a "Create Form 471" task but when they click it they get an error message and are they going to lose funding and if you're the E-Rate expert why can't you fix this error and I think you should keep calling USAC until they fix it otherwise what are we paying you for.

Wednesday, April 19, 2017

The proper definition of a man

Chairman Pai sent two letters to USAC this week, one detailed and dull, and one vague and juicy.  So of course, I'll share a reckless summary and my ill-considered opinions.

First, the detailed but dull.  The Chairman instructs USAC to change the way it determines how large a reserve it must maintain.  It seems that the Chairman is undoing changes that were made in a 2014 letter from the former Chairman.  I think the 2014 letter was fulfilling the then Chairman's promise to "free up an additional $2 billion."  Here's how I see the changes:
Category 2014 guidance New guidance
Pending applications (no FCDL yet) 100% for 3 most recent years
0% for older years
(unless USAC wants to)
Committed, but not disbursed  90%ish  100%
Pending appeals 0%
(I think that's what it says)
So the Chairman is deleveraging the fund.  That's OK with me, but a little surprising, since it means USAC will have to jack the Contribution Factor to cover pending appeals.  Or perhaps the Chairman needs that Contribution Factor jump so he can make a case that the fund needs to be reduced....

Second, the vague but juicy.  The first paragraph is nice, and repeats the "E-Rate is a program worth fighting for" tag line, but the second paragraph starts with "Unfortunately, it has come to my attention...."  Oh, this is going to be good.  The complaints:
  • EPC is a disaster.
    • Not fully operational: invoicing still outside EPC.
    • FCDLs, COMADs, appeal decisions have been delayed.
    • The budget was $19 million, we've spent $30 so far, and the cost could reach $60 million.
  • Lack of USAC transparency with the FCC.
    • USAC didn't tell the FCC that the invoice extension tool was broken, and applicants also couldn't apply for extensions using "Submit a Question," either.
    • USAC is spending more on outreach, and applicants still don't know what to do.
The remedy?  USAC has to promise to:
  • Focus on administration (meaning fixing EPC) before "activities ancillary to proper administration."
  • Be fully transparent with the FCC.  Don't let the FCC get blindsided by applicant complaints.
  • Identify alternatives to be used in case of IT failures.
USAC gets a month to come up with a plan to accomplish those things.

My opinions on the remedies:

I'm in complete agreement that EPC is a failure.  Unfortunately, the Chairman told USAC to "focus first on supporting and completing the basic EPC functionality...."  When it comes to EPC, I'm on the "repeal and replace" team.  I don't think money spent on EPC is money well spent.  I understand it feels bad to dump a system in which we've invested $30 million, but let's not fall prey to the Sunk Cost Fallacy.  Stop spending on EPC, let it limp along, and start building a real portal.  Alas, it's too late to complete development by FY 2018, but let's set a goal of creating a great portal by FY 2019.

"Fully transparent"?  Be careful what you wish for.  The FCC shouldn't try to know everything USAC knows.  First, it will be like drinking from a fire hose.  Second, the FCC should just oversee; if they're going to wade that far into program administration, what do we need USAC for?  The FCC can just contract directly with USAC's sub-contractors.  And hey, FCC, before you start taking a more active role in E-Rate administration, how about you do your own job first?  By which I mean, decide the huge pile of outstanding appeals that has been building for the last 10 years.  Thanks to the changes in reserve requirements mentioned at the start of this blog post, those appeals are going to force USAC to sit on a huge pile of money.  (In his defense, the Chairman has already said he thinks the FCC should meet its appeal decision deadlines, so maybe the appeal backlog is going to decrease.)

"Alternative the event of IT failures"?  Some other ways to express that idea:  "redundant" and "failover" systems.  So the FCC is willing to admit that it needs failover in its own IT operations, but won't pay for failover in applicant systems.  Sauce for the goose?

I was nodding my head while the Chairman was ripping USAC a new one, but once he started on solutions, I found myself shaking my head.

Tuesday, April 18, 2017

School drain, library flight

Another year, another 3,000 applicants leaving the program.  Funds for Learning has released an analysis of the number of applicants posting Forms 470.  What does it show?  Since 2014, about a third of the non-district schools and libraries that were applying have stopped.  But as I've done before, I'm going to look at the total percentage of entities applying for E-Rate.  I'll use data from NCES, and say there are 13,588 districts and 33,366 private schools in the country.  And I'll use IMLS data to say there are 9,082 libraries in the country.  Based on those numbers and FFL's data, here are the participation rates:
2014 2017
Districts 97.2% 84.7%
Schools 25.1% 17.1%
Libraries 43.6% 27.9%

That's a pretty quick drop.  Why?  Here are my speculations:
  1. Voice phase-out.  Many smaller applicants are at the point where it no longer makes sense to fill out the forms.  Because the only service for which they can get E-Rate funding is their cable modem, which might cost only $960 per year.  At a 40% discount rate, that's $384/year in funding.  Let's take the ridiculously optimistic Burden Hours that the FCC put on the forms, it takes 9.5 hours to do the 4 forms.  That would be $40/hour.  But that doesn't count the time spent learning the rules, which are splattered across the USAC Web site (781 pages last time I counted) and FCC orders (over 500 orders last time I counted).  Sorry, just not worth it.
  2. EPC (and that system we had for one year before EPC).  Having to learn a new interface is a big time suck.  Making applicants learn two new interfaces in subsequent years was too much.  I can't say for sure that it drove applicants out of the program, but it certainly got me a bunch of new clients.
  3. The Form 498.  We really had trouble convincing some clients to certify that form because: 1) they didn't want to give out banking info, and 2) they very much preferred paper checks to electronic payments.  Another change that jarred people.
How can we get the participation back up? Here are some suggestions off the top of my head:
  1. Fix EPC.  Even better, burn it down and start from scratch.  Step 1: set a timeline, letting everyone know at least a year ahead of time when the new system will be out.  Step 2: ask users what they would like to see in a portal.  Step 3: release a beta; we consultants would be happy to kick the tires.
  2. Simplify, simplify, simplify.  Get the FCC out of the business of regulating how a school district decides whether to pay $79/month for Internet access to Comcast or FiOS.  Make P2 budgets district-wide. Etc.
  3. Dump CIPA.  OK, the FCC can't just give it the heave-ho, but it seems like someone should point out to Congress that CIPA requirements are keeping a lot of libraries and some private schools out of the E-Rate program.
  4. Can the filing window.  With voice gone, P2 capped and the cap raised, we haven't come close to hitting the funding cap.  Which means we don't need a filing window.  Allow applicants to make purchasing decisions when they want and file when they want.

Saturday, March 25, 2017

Reading the Pai leaves

Reading this week's Funds for Learning Guidenotes, I learned of a letter from Chairman Pai to Senator Nelson, in response to a letter from the Senator, concerned about the Chairman's rescindification of an earlier report.

First, of course, the most important issue: the capitalization of the "R" in "E-Rate."  Faithful readers will know I have for years been keeping track of this for years.  The Chairman used the big "R"!  Our proud program deserves nothing less.

As I mentioned in a comment in February, some senators were not pleased that Chairman Pai rescinded and revoked an earlier E-rate Modernization Progress Report.  The first letter of concern came from Senator Bill Nelson.  [Is it just me, or does he look an awful lot like Michael Palin?  Looking at his web page, I can just about hear him saying "pining for the fjords."]  The Senator's letter didn't say much other than "Hey! Watch it, pally. Step away from the E-Rate funding."  The Chairman's response was basically, "No, no! I was just trying to polish it! I would never dream of damaging such a beautiful thing.  Let's make it even more beautiful!  I only revoked that report because it was released without the approval of the majority of Commissioners [which would have been impossible because Commissioner Rosenworcel's reappointment was being stonewalled by the Senate, so the Commission was split 2-2].  The revocation wasn't because I don't like the report."

But I'm digging deeper, reading meaning into the Chairman's words that he probably never intended, and giving my irresponsible response.  To wit:
  • "Four years ago, I said that 'E-Rate is a program worth fighting for.'"  Yes, he did.  And it's nice to hear him say it again.
  • "student-centered approach":  I'm not as excited to hear that repeated.  The Chairman has in the past used "student-centered" when he's talking about per-student formulaic funding.  I've been consistently ambivalent about formulaic funding since 2005.
  • "complicated, outdated priority system": Well, technically it's now an updated "category" system, not an outdated "priority" system, but point taken.  I don't like the categories either, but removing them will create winners and losers.  It is certainly involved in some ridiculous complexity, but I would argue it's not the source of the problem.
  • "streamline the E-Rate funding process":  Hear, hear!  Call me, I have some ideas.
  • "obtain funding without having to fill out seven different series of forms...": Yes!  Wait, 7 series of forms?  I'm assuming he meant "series of seven forms," but what 7 forms is he talking about?  Well, there's the Unavoidable Three: 470, 471 and 486 .  If you don't want (or can't get) discounted bills, you'll need the 498 once and the 472 annually.  Then there's the 479 and 500, though I'll bet most applicants don't even know those exist.  Let's not forget the numberless form that you have to fill out to get an FCCRN.  And then there are the not-quite-forms-but-submissions-with-required-fields: BEN creation, service substitutions, SPIN changes, RAL corrections, appeals, etc.
  • "...or spend...funds...on outside consultants":  Hey, now!  I resemble that remark.  The Chairman doesn't like consultants, but I think it's a waste of time to focus on cutting out consultants.  We're not a problem, just a symptom.  Truly simplify the program, and fewer applicants will need consultants, and probably pay less if they choose to use a consultant.  But is there any way we can just keep making the program more complicated until my youngest gets out of college?
  • "end the incentives for wasteful spending":  Yup.  To start, cut the top discount from 90% to 65%.  And then maybe look at the recommendations of the WFA Task Force from 2003.
  • "distribute funds more fairly":  Beware government officials saying "more fairly"; what it really means is "more in agreement with my priorities, which I'm not sure you'll agree with."  Everything government does involves taking something from someone and giving it to someone else, so every government action seems unfair to someone.  Based on the Chairman's past statements, I think what he really means is "give more funding to rural applicants."  To me, that's not more or less fair.  Let's be open about what the priorities are for the program, and then distribute funds according to our priorities.  But don't call it "fair."
  • "much more transparent":  I'm all for that; the secrecy in this program is astonishing.  You want to get rid of consultants?  End the secrecy.  How about starting with publishing the 700 pages of secret rules?  And then create a book with all the rules.  And implement a recommendation from the Report on FCC Process Reform: "developing a detailed inventory of pending matters, and, over time, making that inventory public."  That means publishing a list of appeals currently pending at the FCC.  I hope this means the Chairman is abandoning his idea that the way to make new rules could be: "my four colleagues and I could all get together in a room and try to hammer out a deal."
So I like most of what he said, and I don't hate any of it.  Of course, that's often the way things start out in government, and then it gets down to the nitty-gritty and suddenly no one likes it. But you know what I liked?  Not a whiff of a suggestion that the program needs to get smaller.  Of course, if I were the Chairman trying to reassure a Democratic senator, I wouldn't mention my parsimonious desires, either.

Saturday, March 18, 2017

Index? What index?

At first, I thought, "Oops!"  Then I thought, "Wait a minute!"  Then I thought, "What the hell?"  Then I thought, "Holy crap!"

Earlier this week, I blogged about the increase in the $150-in-5 cap to $151.50 for 2017-2018 due to an inflation index, and whined about how the increase was lower than it should have been.  Then today, I read on Funds for Learning's site that the increase to $151.50 was for FY 2016-2017 (a 1% increase), and the FY 2017-2018 cap was increased to $153.47 for  (a 1.3% increase).  "Oops."

But "wait a minute," I was sure that wasn't what E-Rate Central said.  I checked, and while they have the correct information up now, they do have a footnote acknowledging that they had earlier had the info I used for my reckless blog.

"What the hell?"  Why are we finding out about this because E-Rate Central noticed that the Category Two Budget Tool was using $151.50 for FY 2017-2018?  The FCC has said nothing.  USAC has said nothing.  How is it that this change is being made without telling anyone?  How is it that this change was made last year without telling anyone?  Why are we forced to rely on E-Rate consultants to make this public?

"Holy crap!"  Why didn't anyone notice the increase for FY 2016-2017?  Because it didn't happen.  USAC used $150/student to calculate FY 2016-2017 C2 budgets, and forced applicants to reduce their funding requests to fit under $150/atudent.  Wow.  All those applications were incorrectly reduced.

But what now?  For most of those applications, it's been more than 60 days, so the reduction can't be appealed.  And technically, PIA didn't reduce the applications.  They just told the applicants that they were over budget, and made the applicant tell them what they wanted to remove from the request.

If USAC correctly handled requests that are over budget, the fix would be simple.  See, what PIA does now is say that if a request goes over $150/student, the excess is ineligible.  Wrong.  It's still eligible, just over cap.  It should be handled the way USAC handles invoices that are over the committed amount; you put the full amount on your invoice, and USAC just says, "Yeah, we're only giving you what you were approved for."  Likewise, in the case of a request that exceeds the $150/cap, the Committed Amount should just be reduced to the cap.  If USAC had just done that, they could now just say, "OK, we'll just up those FRNs to what the cap should have been."  That wouldn't be a complete solution.  Those applicants that reduced the size of their request before applying would still be screwed.  But at least some of the damage could be easily repaired.

By the way, I checked the Category Two Budget Tool, and it looks to me like it's currently using $150/student to create budgets.  Am I missing whatever E-Rate Central spotted, or did someone change the tool back?

I have complained about the secrecy in this program since 2006, but now we've reached a whole new level: rules so secret, even USAC didn't know.

Wednesday, March 15, 2017

That appealing new system

I had the misfortune of needing to look through the most recent USAC annual report, and noticed something I hadn't before: the number of E-Rate appeals jumped from 447 in the 3rd quarter to 1,191 in the 4th quarter.  Yowza!

Maybe it's a seasonal thing?  Not so much.  The year before the totals were 387 for Q3 and 505 for Q4.

Now what could have caused appeals to double?  I'll give you a hint: it starts with "E" and ends with "PC."

Pittsburgh paranoia

Chairman Pai gave a speech at Carnegie Mellon and said something that seemed good at first, but then got me worried.  Here's what he said: "...any direct funding for broadband infrastructure appropriated by Congress as part of a larger infrastructure package should be administered through the FCC’s Universal Service Fund (USF)...."  

Right off the bat, I was encouraged that the Chairman wanted to see the USF grow.  Then my paranoia kicked in.

Since 2005, I have been harboring a paranoid suspicion that Republicans in Congress want to get the USF into the Treasury so it can be bled dry.  We've been saved by the fact that the E-Rate is not funded by Congress, so money cannot be taken from the E-Rate to pay for other priorities.  But if the Chairman's wish is granted, then part of the USF will be funded by Congress.  Once the USF gets a taste for money from the Treasury....

And then it got worse: "...targeted to areas that lack high-speed Internet access."  Oh, no, is this Commissioner O'Rielly's "no fiber funding for counties that have fiber" idea?   The Chairman then says that programs should "reduce wasteful spending by preventing subsidies in areas where the private sector is already investing in networks, so there’s no risk of government investment in overbuilding."  I don't like the sound of that.  One person's "overbuilding" is another person's "competition."

But then I found hope in a single letter: the "s" in "networks."  Now there's a waste-reducing standard I can get behind: the USF won't fund new fiber if multiple broadband providers have fiber installed that can serve their locations.  Unless, of course, self-provisioning would save money for the E-Rate program.  Oh yeah, that's right: applicants already can't self-provision unless it saves money for the E-Rate program, regardless of whether any fiber is near any of its locations.

And finally, a couple of observations about Chairman Pai's speech, which have nothing to do with E-Rate:
  1. The Chairman opened his speech with some banter about the Steelers beating the Chiefs.  Does anyone else think that of all the places in Pittsburgh, the Software Engineering Institute at Carnegie Mellon is the most likely to be filled with people thinking, "Who are these stealers?  And why are they beating chiefs?"
  2. The Software Engineering Institute played Blackgate Prison in The Dark Knight Rises.  The Chairman's speech, focused on how to "help bring the benefits of the digital age to all Americans"  was definitely better than Bane's message of chaos.

Tuesday, March 14, 2017

What's the index, Kenneth?

Inflation is popping up everywhere this week.

First, the FCC has announced the cap increase for the E-Rate program for FY 2017-2018.  Normally, this would be a boring non-event, but I'm a little surprised that the new FCC Chairman is letting the fund grow.  Yes, the inflation index is in Commission rules, but surely some kind of special stay is possible.  More likely, the Chairman knew it's a fight not worth fighting: since the cap was raised from $2.25 billion to $3.9 billion, demand hasn't hit the cap.  So raising the cap 1.3% is meaningless.

What's this in footnote 2?  "This represents a $51,207,000 increase for the E-rate program funding cap as a whole, including a $38,077,000 increase for the category one services funding level and a $13,130,000 increase for the category two services funding level."  Why are they bothering to keep track of the increase to the non-existent $1 billion C2 set-aside?  Oh, it's in the rules.  Well, at least the WCB only wasted 5 minutes figuring that out.  But each year, due to the compounding increase, they'll need more time; in a decade or so, they'll be wasting 10 minutes.  (The draft of the EMO actually set aside $1 billion for C2, but before approval, that was changed to a sort of aspirational guideline.  Now the $1 billion which is not set aside for C2 has increased to $1.01 billion not set aside for C2.)

But here's an inflation calculation I missed.  In E-Rate Central's latest "News for the Week," they point out that the $150 in the $150-in-5 Rule is indexed to inflation.  And they've confirmed that USAC has increased the C2 budgets to $151.50/student.  That's actually not as pointless as calculating the increase to the non-existent C2 set-aside, and will probably have more of an impact than the cap increase  for the whole program.

But the math seems wrong.  They've increase the $150 to $151.50.  But shouldn't they use the FCC's inflation figure of 1.3%?  That would give us a $151.95-in-5 rule.  Is someone skimming that 45-cent difference?  Troubling if true.  Someone should demand a congressional investigation.  I'm kidding.  (Ever since the Dinner Table Rule made it into an NPRM, I feel like I have to make clear when I'm joking.)

I'm assuming that the $9,200/building minimum will also be indexed.  So those tiny schools and libraries that already blew their entire $9,200 budget will get a $119.20 windfall this year!

Eensy-weensy good news all around!

Monday, March 13, 2017

Is Melissa C1?

Some recent sponsored content over at E-school News touts in it's headline "a new E-rate funded technology."  And I'm hearing alarm bells.  Let's have a look.

First problem: the small "r" in "E-Rate."  At least it's better than the old eRate, but I'm still going to mangle the name of the publication until they get it right.

Second problem:
"When virtual routers are bundled together with [advertiser's] Switched Ethernet service, this combination may be eligible for E-rate support as a Category 1 service."
followed by a footnote that says:
"[Advertiser] does not represent or guarantee the eligibility of any service or product."

Yeah, they did say "may be eligible," but still....

Is virtualized router service eligible under C1?  Let's go to the Eligible Services List.

That pesky "basic conduit access to the Internet" phrase is still in there for C1.  Back when the ESL was more descriptive, virtualized add-ons were excluded from "basic."  Now the ESL doesn't have exclusions (except when it does), but I still say virtualized routers are not "basic."

Virtualized router service is eligible: "Functionalities listed above that can be virtualized in the cloud... like routing and switching, are also eligible."  [I know that ellipsis is a sneaky change in what the sentence actually says, but it makes a nice quote.]  Problem is, that's under C2.  So virtualized routers are certainly eligible, but almost certainly only under C2.

And who gets stuck holding the bag if it turns virtualized routers aren't eligible?  The applicant.

Saying virtual routers "may be" Category 1 is like saying
Melissa McCarthy may be the next White House Press Secretary.*
*I do not represent or guarantee the identity of any White House staff.
[Think about it, though.  I'd watch every press conference if Ms. McCarthy were giving them.  The ratings would be HUUUGE.]

Saturday, March 04, 2017

And what about Guildenstern?

Is this the final nail in former Commissioner Rosenworcel's term at the FCC?  On February 28th, President Trump withdrew the nominations of Commissioners previously nominated by Obama, and Ms. Rosenworcel is on the list.  No one seems to know why those names were withdrawn.  In the past, the President has looked to Congress for nominees from the opposing party, but that's just a tradition: the President can nominate any non-Republican he wants.  Or, I suppose, nominate no one and leave the FCC with 3 commissioners

Commissioner Rosenworcel's reappointment was blocked by the Senate (after unanimous approval by the Commerce Committeefirst by Republicans, then by Democrats, then by Republicans again.

Hey, "borked" became a verb, so maybe we'll be saying that Ms. Rosenworcel got "garlanded." Or maybe we should use "merricked," so people don't think of Judy Garland or imagine the former commissioner festooned with Christmas decorations.  But will "merrick" conjure up the Elephant Man?  Except Ms. Rosenworcel got a confirmation hearing and committee vote, just not a full Senate vote, so she wasn't exactly merricked.

What's going to happen next?  Even I can't speculate.

Monday, February 13, 2017

Get fiber while the getting's good

Looks like Commissioner O'Rielly is coming after self-provisioned fiber.  This is nothing new.  The Commissioner's first blog post included the statement "E-Rate funding must leverage the private sector networks and services, not overbuild them."  The most troubling part of the letter: "Regardless, I see absolutely no justification for using E-[R]ate funds for such a purpose.  Instead, any universal service funding for broadband deployment should be targeted, through the high-cost program, to unserved communities most in need of support."  It's that "regardless" that sends a chill up my spine.

But before we get to the meat of the letter, let's look at the most important question: Did the Commissioner use a small "r" in "E-Rate"?  He did.  That's disappointing, especially because back when he first arrived at the FCC, he used a capital "R."  Did the mole get to him?

I disagree with the Commissioner's position for a few reasons:
  1. The current rules require that a district prove that self-provisioned fiber is cheaper than existing networks.  The E-Rate only pays for self-provisioned fiber when it is cheaper than the existing service.  So in every case, self-provisioned fiber is reducing the amount of E-Rate funding needed.  It's the opposite of wasteful.  I have a client that built a self-provisioned network before it was eligible for E-Rate, because it saved them money, even with the E-Rate putting a thumb on the scale by discounting service from the existing network and not from the self-provisioned network.  Even with a 40% discount, the existing service providers' networks were more expensive than undiscounted private fiber.  Maybe self-provisioned isn't always cheaper, but the E-Rate will only fund it when it is cheaper.
  2. The Commissioner seems to be saying that self-provisioned fiber shouldn't be allowed if "there is already at least one private broadband company operating in the county...."  That is a troubling line of thinking.  Forbid competition, even when it reduces reliance on E-Rate funding?
  3. This seems like an extension on the FCC's fear of "duplicative" services.  I'd invite the Commissioners to talk to their CIO about the Commission's infrastructure.  I'll bet the CIO won't say "duplicative," but will mention "redundancy" and "backup" as virtues.  I'm all for eliminating waste, but duplication is not necessarily waste when it comes to technology.  In IT, "redundant" is good, and "single point of failure" is bad.
  4. I don't like "overbuild."  Instead, let's say "encourage competition" or "break monopolies."  Commissioner O'Rielly doesn't want to "support artificial competition."  I say we should support any kind of competition we can.  I'd prefer organic competition, but artificial is better than none.
  5. The Commissioner says, "Overbuilding is especially problematic when those existing networks are subsidized by other federal funding...."  Wait, so we give one service provider a leg up on installing fiber, and then deny other providers who can install new fiber and beat the price of the subsidized network?  Is that fair?
  6. The Commissioner says he hears concern about overbuilding "[i]n meetings with outside parties...."  Those outside parties wouldn't be the incumbents who currently have a monopoly on installed fiber, would they?  What did the E-Rate applicants say about overbuilding when you talked to them about it?  You are having as many meetings with applicants as you are with service providers, right?
I have to say, he does have a good example attached to his letter.  The applicant says that the self-provisioned fiber will be a "backup system" to a county-wide fiber network now being installed "until we know that [the county WAN] is complete and fully functional."  OK, that seems like a bad reason to build your own fiber network; private fiber is a long-term investment, and the new fiber won't be up before the county WAN.  And if the county WAN includes redundant connections to each school and a redundant connection to the Internet, then it does seem unnecessary to build another network.  But the district would have to kick in half the cost of the WAN (they have a 50% discount), so they seem to believe that the service is worth paying for.  (Or at least potentially worth paying for; the bids aren't in.)  Because self-provisioning will be cheaper.  For the applicant and for the E-Rate program.

What's an applicant to do?  Get your self-provisioned fiber application in now.  I smell changes in the eligibility of dark fiber for FY 2018-2019.  Also, make sure to use the option to get the entire E-Rate payment in the first year.  When weighing whether to self-provision, don't factor in E-Rate funding past 2017-2018.  Because as the Commission's recent order reiterates, "A multi-year contract does not insulate applicants and service providers from changes in program rules, including changes to the eligible services list...."

But even FY 2017-2018 is not going to be smooth sailing.  Commissioner O'Rielly has requested a bunch of info from USAC on self-provisioned networks.  Ugh.  Approvals of self-provisioned fiber for FY 2016-2017 were delayed over 6 months while USAC figured out what info they needed and how to approve those requests.  I had been thinking that maybe next year would go more smoothly, but I'll bet this is going to throw USAC into uncertainty and self-doubt.  I know it's thrown me into uncertainty.

And here I thought the E-Rate would be left alone for a year while the Commission went after bigger (and less popular) fish.

Thursday, February 09, 2017

Waive that mess

Well now, there's something you don't see every day: the FCC fixing a problem before applicants have to go through the deny-appeal-appeal dance.  I've already ranted about what a mess the FCC created by saying that connections between 2 schools in the same building were C1 (scroll down past my whining about streams, roads and campi).  Now the FCC has, without anyone asking, fixed it in a new Order.  Basically, they waived the mess for 2017, which will give them a chance to fix it in next year's Eligible Services List.

And there's more good new in footnote 24.  The text there makes it pretty clear that if a school's campus had a road running through it,  and the district considered them two campuses, then they can stay two campuses.  That footnote even makes it sound like any district can decide to divide up a campus into a bunch of smaller campuses if there are roads or streams running through the campus.  It's not much of a clarification, but at least it gives the impression that the FCC was trying to give applicants more flexibility in determining what a "campus" is.

Friday, February 03, 2017

Set wide the window. Let me drink the day.*

At last, the filing window has been announced!  Opening February 27, closing May 11.

Buried in the middle of that announcement is a new procedure you need to pay attention to: this year we have a sort of storm window.  This year, all entity information, including enrollments and NSLP, will be locked when the window opens.  So you've got 3 weeks to make sure that you have all the correct entities in EPC, and that the entities have the correct info.  How many RALs is that going to create?

Here's a little historical context:
Fund Year FCC releases ESL  Window announced Days passed Window open 60 days? Window close Window days
2005 10/14/2004 11/5/2004 22 12/14/2004 61 2/17/2005 65
2006 11/22/2005 11/23/2005 1 12/6/2005 14 2/16/2006 72
2007 10/19/2006 10/20/2006 1 11/14/2006 26 2/7/2007 85
2008 10/19/2007 10/28/2007 9 11/7/2007 19 2/7/2008 92
2009 11/21/2008 11/24/2008 3 12/2/2008 11 2/12/2009 72
2010 12/2/2009 12/3/2009 1 12/3/2009 1 2/11/2010 70
2011 12/6/2010 12/10/2010 4 1/11/2011 36 3/24/2011 72
2012 9/28/2011 11/22/2011 55 1/9/2012 103 3/20/2012 71
2013 9/27/2012 11/13/2012 47 12/12/2012 76 3/14/2013 92
2014 10/22/2013 11/20/2013 29 1/9/2014 79 3/26/2014 76
2015 10/28/2014 12/19/2014 52 1/14/2015 78 3/26/2015
(ext. to 4/16/2015)
81 (102)
2016 9/11/2015 1/25/2016 136 2/3/2016 145 4/29/2016
(ext. to 5/26/2016)**
86 (113)
2017 9/12/2016 2/3/2017 144 2/27/2017 168 5/11/2017 73
** Extended to 7/21/16 for consortia and libraries
Some explanations:
"Days passed" is the number of days that passed between the release of the ESL and the announcement of the window dates.
"60 days" is the number of days between the release of the ESL and the opening of the window, which should be at least 60 days per the Third Report and Order.
"Window days" is the number of days that the window is open.

This year's timing is similar to last year's unprecedented timing, just pushed back a couple of weeks to fit in the "pre-window" entity correction window.  (And last year's got pushed back further during the window.)

*Edith Wharton

Thursday, February 02, 2017

So far, so good

I'm liking the first change that I've noticed Chairman Pai make.  He's making the FCC more transparent.  No, really.  He's released to the public the documents that the FCC will be voting on at their next meeting.  In the past, the public didn't get to see those documents until after the meeting (in the case of the E-Rate Modernization Order, 10 days after the meeting).

That's a good change.

Even better, he's trying it out with a couple of documents to see how it works before making it a rule.  I am very happy to see the Chairman testing his ideas before committing to them.  That bodes very well for a decrease in unintended consequences.  I didn't expect Commissioner 3.14159... to make the FCC more rational.

Monday, January 23, 2017


Well that was quick: Commissioner Pai is now Chairman Pai.  It's not a surprise, and it is good to have the decision made.  But is it good for the E-Rate?

Let's look at the most important question first: does the new Chairman capitalize the "R" in "E-Rate"?  Yes!  But can he root out the Russian mole at the FCC that has been weakening our country's R?  Make the "R" in "E-Rate" great again!

What effect will Commissioner Pai have on the program?  At this point, it's mostly speculation, but I can't help myself.  It's hard to predict what the Chairman's priorities will be now that he controls the agenda, rather than just reacting to it.  Here are some thoughts based on his past statements.

Things I like:
  1. Big picture: the Chairman is not afraid to think outside the box and suggest big changes.  That's a little frightening, but I've been frustrated by recent reforms that just nibbled around the edges and tacked on a few new little facets.  He also seems to keep the needs of applicants foremost in his mind.
  2. Chairman Pai often deplored the partisanship and lack of collegiality in the FCC.  I have to agree.  Let's hope he can return the FCC to a less partisan body.
  3. He has said we should simplify the application process.  Yes!  Some of his proposals (while I didn't agree with all of them) could actually lower the workload on applicants.  I hope he really can simplify the process.
  4. As part of that simplification, the Chairman has suggested removing competitive bidding requirements from the E-Rate.  I'm all for that.
  5. The Chairman proposed a single discount rate for all applicants.  I don't actually like a single discount rate, but I do support simplification of the discount matrix.
  6. And that single discount rate would be 75%.  It's good that it's lower than 90%, which is too close to free, but I'd rather have the top discount rate be 65%, like it is over at the Rural Health Care program.
Things I don't like:
  1. Big picture: Chairman Pai has said, "E-Rate is a program worth fighting for," but has also said that he wants to reduce the size of the Universal Service Fund contribution factor, and seems willing to reduce the E-Rate program to do it.
  2. In the most recent statement I've found, the Chairman said, "We need to fire up the weed whacker...," but he seemed to be talking about Net Neutrality, not the E-Rate.  Still, I don't want anyone using a weed whacker near our little rose garden.
  3. The Chairman has suggested a per-student funding allocation, called "formulaic funding" in 2005 and "student-centric" funding when it was reheated in 2013.  Basically, take the current $150-in-5 budget for C2, and make it $32/student/year, including C1 and C2.   I'm not all that sanguine about per-student funding.
  4. The Chairman has said recently and repeatedly: "It is time to bring more openness and transparency to the FCC."  That's great, but it turns out what he meant is openness between commissioners, not transparency to program participants.  It appears that he means, at least in part, allowing Commissioners to meet in private.  That isn't good.
  5. Chairman Pai hates consultants, and has falsely implicated us in fraud perpetrated by service providers.
Other things:
  1. Chairman Pai sure sticks up for rural applicants.  When he talked about his budget concerns with modernization proposals, he was very concerned that rural schools were going to lose all their funding, when in fact, non-rural schools would lose funding first.  And his E-Rate 2.0 proposal included giving rural applicants twice as much funding per student as non-rural applicants.  I think it is true that rural areas are less likely to have the concentration of poverty necessary to reach a 90% discount, which meant the P2 gravy train didn't reach them, but I'm not so sure that rural applicants always need more money that non-rural applicants.
I don't think E-Rate will be at the top of his priority list, so the program should be stable for a year or two.  But then, watch out.

Saturday, January 21, 2017

Spam, spam, info, spam

Bad news for people who are General Contacts for entities in EPC.  USAC has released a new Entity Download Tool that will let anyone (without needing EPC access) download their name and email address.  Account Administrator's names are also available, but not, apparently, their email addresses.

Browsing the NJ entities, most entities do not have an email address listed (most don't have a General Contact name, in which case sometimes the Account Administrator's email is sometimes listed).  I haven't figured out a pattern on which General Contacts get their email address exposed.  Still, there are thousands of school and library employees should brace for an increase in spam.

Saturday, January 07, 2017

Don't ask, and definitely don't tell

Wow.  Just wow.

As I reported back in 2009, the FCC got an appeal from a district which had discovered that one of its employees and the president of a service provider had defrauded the E-Rate program of $5 million and alerted the police and USAC.  The actors were imprisoned and ordered to pay back $2.1 million.  Then USAC let the district and the service provider company know that they were liable for the other $2.9 million.  The district pointed out that they never got any of the equipment or the money, so USAC should just go after the service provider and the two individuals who ran the scheme.  Seems like a reasonable request, especially since it was the district that told USAC about the fraud.

Last week, the FCC reached a decision on the appeal, and it's a doozy.

They affirmed the USAC decision, and said that recovery should come from both parties.  Is it just me, or does that seem kind of unjust?  My favorite line: "Not recovering ... because other officials were unaware of his criminal conduct would discourage E-rate applicants from creating internal review systems necessary to prevent waste, fraud, and abuse."  Think that over: this district is going to lose $2 million because it reported fraud to USAC.  To the extent that other E-Rate applicants are even aware of this decision, it provides a strong incentive not to report fraud.

And what does it mean that USAC will recover "jointly" from the district and the service provider?  It sounds like they'll go after them both until one of them pays up.  What do you think the odds are that the service provider company is still in existence?  It seems like the district is going to end up paying the whole $2.9 million.

But it gets worse.  The FCC took it one step further.  They noted that the perpetrators had not paid back most of the $2.1 million they were fined, and decided that the district should be on the hook for that, too.  Since the malefactors only coughed up $784,338 of the $5,050,431 that was stolen, if the service provider is no longer in business, it looks like the district is going to have to pay $4,266,093.  Over $4 million lost because they caught and reported an employee stealing.  That will certainly "discourage E-rate applicants from creating internal review systems necessary to prevent waste, fraud, and abuse."

And the perpetrators?  The guys who pocketed $5 million and only had to pay back $784,338?  Their debarment from the E-Rate program expired back in September 2008.

Friday, January 06, 2017

When USAC closes a door...

Hey, isn't there supposed to be a window around here somewhere?  It's usually someplace close to this.

When will we know?  Well, last year they announced on January 25th that the window would open on February 3rd and close on April 29th.  (Of course, it didn't close until May 26th (July 21st for consortia), but that's another story....)

E-Rate Central has some interesting guesswork.  The bottom line: window opens in early March, closes in early May.  Could be.  They mention several steps that have to happen first, and give USAC a pretty tight timeline to get it done, so I wouldn't be surprised to see those dates slide.  Also, at the DC training this year, I heard that the target for window length is 75 days, so if it opens in early March, maybe it would close in late May.

In any case, I'm feeling pretty confident that once again, I will get my wish to have the window close in May.  Of course, when I made that wish, I should have realized that closing the window later wouldn't necessarily make the PIA process less onerous.  Instead, six months into the funding year, USAC has only committed $1.64 billion out of an estimated $3.6 billion in requests.  Even if there have been some denials, halfway through the funding year, half the funding requested is still waiting.  (And about $500 million of that $1.64 billion was just approved in December.)  True, over 80% of applications have been approved, but over half the dollar amount is just hanging there.  (Here's a nice Funds for Learning graph as of December 15th.)

"Be careful what you wish for" comes to mind.

Thursday, January 05, 2017

Can't swallow SIP

Time for me to complain about the use of the English language again.  Today's complaint: the misleading jargon surrounding SIP.

SIP ("Session Initiation Protocol") is a protocol which can allow two devices to communicate, usually to set up a VoIP call.

Applying old-school telephony terminology to VoIP has created misunderstanding.  A “SIP trunk” is not actually a trunk, but it replaces trunks, so lazy telecom folks gave it that name.  SIP does not have “call paths,” but because the simultaneous-user limits behave like old call paths, people use that term.

SIP is not involved in the actual transport of voice or anything else.  It just sets up (and later tears down) the connection between two devices.  Once the connection is established, communication goes directly between the two phones using RTP, with no involvement from the provider’s SIP infrastructure until the call is terminated. (When you talk into your VoIP phone, your phone turns that sound into packets and sends them directly to the other phone.)

You can’t run data over a SIP trunk.  First of all, there’s no “trunk,” just a license to use a service provider’s SIP servers to set up and tear down calls.  Second, SIP cannot handle, say, an HTTP request, so you can’t browse the Web using SIP.  We don’t use SIP for anything but VoIP (and maybe some videoconferencing).

It’s like saying that you have an “HTTP trunk” that carries data and audio/video.  It’s a protocol, not a transport medium.  And yes, the use of HTTP does result in you getting to watch Nyan Cat videos, but HTTP’s involvement is to give your browser the info that it needs to get the video from a video server.

So I propose that we outlaw the use of terminology like "SIP trunk" or "SIP call path" in the E-Rate program.

Looking a little deeper, the distinction between “voice” and “data” is mighty fuzzy.  Your VoIP end-user device knows it’s a phone call, and maybe a gateway in your building knows, and your service provider’s SIP infrastructure is aware it’s a call when setting it up and tearing it down, but all the other devices involved (routers, switches, etc.) just see your phone call as a bunch of packets (maybe high-priority packets).

 I’m a visual guy, so I find looking at the OSI Model clears things up for me. 
Each layer translates the info into a format that the next layer can work with.  When an application wants to send info to another node, it works its way down the stack, through a variety of protocols which transform it until it reaches the Physical layer, which is a fiber or wire.  When that signal arrives at the remote node, it works its way back up the stack, being transformed back into something the application at the other end can use.
Some people seem to think that SIP operates at the bottom 4 layers, transporting data.  Nope.  It operates at the top layer.  By the time you get to layer 4, SIP traffic looks the same as all the other traffic riding your TCP/IP network.  At that point, it’s all data.  Saying that data runs over SIP is like saying that fiber runs over IP.  It’s the other way around: SIP runs over your data network and IP runs over fiber.

Your connection to your ISP operates at the Data Link Layer: a signal on a wire (or fiber).  So it seems seems kind of nonsensical to cost-allocate that connection based on whether some of those signals used to be voice (and will be again once they've been transformed by the layers at the other end).

Why does it matter?  Because the ESL says you have to apply the voice discount reduction to "circuit capacity dedicated to providing voice services" (which is language lifted from the E-Rate Modernization Order).  The mistaken belief that SIP is some kind of trunk leads people to believe that it is dedicated to voice and that you can determine the cost of that trunk and cost-allocate.  There is no "dedicated" capacity in a typical IP-over-Ethernet network.

And now a meta-rant:
Who the hell came up with "SIP"?  First off, in the name of a protocol, "IP" should mean "Internet Protocol"; everyone who sees "IP" in an acronym is going to assume it means IP.  And why use the word "Session"?  "Session" already has a meaning in networking (as you can see in the picture above).  How about we rename it "Multimedia Connection Establishment Protocol" or MCEP?  Not as catchy, but also not as confusing.

Kimmy Mentions Wheeler!

Hey, it's time again for a post about something that amuses me and is E-Rate-adjacent.

We're watching "Unbreakable Kimmy Schmidt" on Netflix.  Last night, we reached the episode "Kimmy Sees a Sunset!" (episode 12 of season 2) and suddenly, they're talking about FCC Chairman Tom Wheeler!  It wasn't as good as John Oliver calling the Chairman a dingo, but we do get to hear David Cross say, "Tom Wheeler and I still use floaties!"

Why did this give me a little thrill?  It's not like I've met the Chairman or even follow him on Twitter.  But I am among the very few Americans who can name the FCC Chairman.  And I could pick him out of a lineup, even if the lineup included Michael Keaton and Rutger Hauer.  It's kind of like hearing your favorite obscure band mentioned on the radio.