Someone's head restin' on my knee

I happened across some suggested changes to the program over at Funds for Learning, and I can't resist running my mouth.  The suggestions:

1. Bring back voice
2. Make all network infrastructure eligible (security, monitoring and management are mentioned)
3. C2 budgets should be per-entity, not per-entity.  By which I mean, per-organization, not per-location.
4. C2 budgets should be doubled.
5. The C2 budget floor should be tripled.

To which I say:

1. Let's expand C2 first, and see if we've got money left.  Back when the program ran out of money every year, I think I was the first to suggest throwing voice out of the program.  Now that we don't hit the cap, I'm OK with letting voice back in.  But first, let's fully fund C2.
2. I agree that the per-student cap reduces the need to nit-pick nework equipment.  And all sorts of security equipment should be eligible in any case.  Monitoring and management are a little more questionable to me, but if we're going to pay for MIBS (the "M" is for "managed"), then it seems like management should be eligible, whether it's a service or a piece of equipment.  But what FFL said was, "There should be zero ineligible network infrastructure."  That's a bit too far: let's not let servers back in, or network storage (I'm looking at you, video servers).  But yes, let's allow security, management and monitoring.  It's irresponsible to run a large network without them.
3. Yes, yes, yes!  This should be the FCC's top E-Rate reform priority.  It's a simple change, and would dramatically simplify the C2 process.  And it would give school districts the power to decide where they need equipment, rather than having to live by the fiction that all locations have equal C2 needs.
4. Yes!  My back-of-the-napkin calculations say we should make the C2 cap at least $500/student, and the program could afford $600/student, but doubling would be a step in the right direction.
5. Yes.  Small applicants are leaving this program in droves, so the FCC should do whatever it can to bring them back.

What is the FCC doing about C2, anyway?  When the Wireline Competition Bureau released their Report on Category 2 Funding, I wondered if the next step would be an NPRM.  I mean, it seems like they'd have to do one, no?  They did request comment on C2 budgets back in 2017, but that doesn't count as an NPRM, does it?

If no Order is issued, applicants who applied for C2 in FY 2015-2016, as well as applicants who have never applied for C2, would find themselves back under the 2-in-5 Rule for FY 2020-2021.  (Applicants who first filed for C2 in FY 2016-2017 would go back to 2-in-5 in FY 2021-2022, and so on; as their 5-year budgets expired, applicants would go back to 2-in-5.)

If the FCC is going to release an Order, I'd think it would be before the Eligible Service List is prepared.  At this point, I don't think that leaves enough time for an NPRM.  An interim Order would create more chaos, as applicants try to figure out if they should lock into a new 5-year cycle, or see if something better is coming.

Here's a question that I would not have considered back in 2014: would a return to 2-in-5 be a bad thing?  I mean, the worst part of the 2-in-5 Rule was that most applicants never got a sniff of C2 funding.  With the vastly increased cap and everything but broadband tossed out of C1, we wouldn't run out of money unless applicants started requesting more than $600/student.  That might be enough.  But there are other problems with 2-in-5.  So if we're not going to run out of money, how about we go to 5-in-5?  Request whatever you need whenever you need it.

You can say it's stupid, but in the WCB's C2 report, they said that $150/student was enough. (Well, they said the "budget approach appears to be sufficient for most schools and libraries," but then they went on to talk about how few schools had spent all their money, so they were basically saying that $150/student was enough.  So if applicants don't need more than $150/student, then why not just get rid of the restriction, and let them spend what they need?  Even if applicants spend $300/student every 5 years, we'll stay under cap.  The only argument for keeping the cap so low is that applicants don't need more.

So let's try it: everyone can request all the C2 they want.  If it turns out that the WCB was wrong about C2 needs and demand exceeds the program cap, then approve applications on a first-come, first-served basis.  Yes, EPC might buckle under the weight of applicants trying to be the first to submit, but the strain would probably be less than the current strain at the end of the window.

But wait, why have a gold rush of applicants jumping on EPC at the start of the filing window?  Why have a filing window?  If we're approving applications as they arrive, there is no need for a filing window.  

And since C2 caps and 2-in-5 would both be gone, we'd no longer have a need for C1 and C2, would we?

Well, I did not expect to end up there, but wouldn't it be loverly?