Surf's up?

The FCC has approved the PIA review procedures.  That means that USAC can start approving 471s today.  Based on the PIA inquiries we've received so far, it looks like we're going to start with a "low-hanging fruit" wave of small, simple C1 applications.  That seems like a good move; let all the new PIA reviewers dip their toes in the shallow water before throwing them off the deep end.

Side rant: Since I've been so quiet over the past couple of years, I would be remiss if I did not take advantage of this opportunity to rant about the irony of the FCC issuing public approval of the secret rules by which applications are processed.  Did you know that every year the FCC approves a 700-page set of procedures for processing applications?  (Well, it was 700 pages in 2009, but I'm too lazy to file a FOIA request to find out how long it is now.)  Because the FCC says that the routine processing of funding applications from local governments is a law enforcement action.

So much secrecy.

When can we expect the first wave?  If the recent past is any guide, we should be seeing a wave in April.  Maybe even mid-April.  Of course, it's a new company handling PIA¹, so a delay wouldn't be surprising.
Here's a table of dates from past years:

FY	Window close	Days passed	PIA approved	Days passed	First FCDL	Total days	Million	Apps
2019	3/27/19	0	3/27/2019
2018	3/22/18	6	3/28/2018	23	4/20/2018	29	$501*	15,033*
2017	5/11/2017	1	5/12/2017	14	5/26/2017	15	$47	4,919
2016	5/26/2016	14	6/9/2016	7	6/16/2016	21	$17	2,251
2015	4/16/2015	-27	3/20/2015	62	5/21/2015	35	$151	7,100
2014	3/26/2014	-19	3/7/2014	69	5/15/2014	50	$607	14,600
2013	3/14/2013	57	5/10/2013	19	5/29/2013	76	$130	12,023
2012	3/20/2012	35	4/24/2012	77	7/10/2012	112	$646	23,800
2011	3/24/2011	75	6/7/2011	19	6/26/2011	94	$398	18,500
2010	2/11/2010	91	5/13/2010	13	5/26/2010	104	$429	18,200
2009	2/12/2009	49	4/2/2009	26	4/28/2009	75	$134	6,931
2008	2/7/2008	63	4/10/2008	21	5/1/2008	84	$352	10,000
2007	2/8/2007				4/23/2007	74	$202	21,000
2006	2/16/2006				4/26/2006	69	$184	4,880
2005	2/17/2005				6/27/2005	130	$342	7,700
2004	2/4/2004				4/27/2004	83	$43
2003	1/16/2003				5/1/2003	105	$230
2002	1/17/2002				4/24/2002	97	$233	9,300
2001	1/18/2001				7/23/2001	186	$478
2000	1/19/2000				4/14/2000	86	$253	13,000
1999	3/11/1999				7/13/1999	124	$116	6,000
1998					11/23/1998		$73	3,000

*The FY 2018 first wave was so huge, they released it on in two waves, on 4/20 and 4/21; I'm counting those as one wave.

¹ For those who didn't know, USAC is actually a pretty small company.  All of the application processing (and the Client Service Bureau) is outsourced.  The contract to handle PIA has always gone to Solix (nee NECA Services), but in January, it switched to a company called Maximus.  So far things seem OK to me, but we're just jumping into PIA season.