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As I mentioned in a comment in February, some senators were not pleased that Chairman Pai rescinded and revoked an earlier E-rate Modernization Progress Report.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• "complicated, outdated priority system": Well, technically it's now an updated "category" system, not an outdated "priority" system, but point taken.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.