Part-time student? You don't count.

If I'd gotten around to a full review of the FCC's recent C2 Order, I would have mentioned the problem with excluding part-time students, but Infinity Communications & Consulting did even better, submitting a Petition for Reconsideration.

Basically, the FCC went too far. A few commenters on the C2 NPRM pointed out that having district-wide budgets would simplify the application process for some districts, where students were part-time in two schools in the same district.  True enough.  But for some reason, the FCC went further and said, "In another effort to streamline both the application filing and review process, going forward we will base student counts on full-time enrollment only and eliminate the need for schools or school districts to count part-time students in their enrollment numbers."

I suppose that's fine in states where county-wide districts almost never send students to another district for part of the day.  But not here in NJ (or, apparently, in California, since that's where Infinity is based).  Here in NJ, there are districts that are mostly part-time students.  How?  Well, in NJ, we have more school districts than municipalities.  So way back when, the state created county-wide vo-tech districts.  The model was this: students take all their academic classes at their home high school, and then go to a vo-tech school for part of the day if they want to study car mechanics or cosmetology or culinary arts or whatever.  In NJ, they're called "shared-time" students.  So the vo-tech districts generally had few or no full-time students.  That's been changing at some of the vo-tech districts recently, as the vo-tech districts have expanded into full-time programs, but some of the vo-techs still have a significant portion of "shared-time" students.  Now, the state of NJ reports "full-time equivalent" enrollment numbers to USAC, so a shared-time students only counted as half a student.  That seems fair, no?

But under the new rules, shared-time students can't be counted by either district.

I probably shouldn't point this out, since USAC probably doesn't realize that the state has been including half-students in their enrollment numbers (though they should have realized it, since enrollment totals for a school can be, for example, 232.5).

So how about instead of "simplifying" things by not counting part-time students, the Commission just says, "Whatever the state says your enrollment is, that's your enrollment."

Miffed about NIFs

Once again, SECA is the voice of reason.  They've submitted a Petition for Reconsideration, asking the FCC not to implement the heinous new shared C2 NIF cost allocation rule.  What am I talking about?  It's a rule (tucked in paragraph 51 the new C2 Order) that requires applicants buying new shared C2 equipment (a firewall used by the entire district, for example) to reduce the eligible cost if that equipment serves a NIF in addition to schools.  So if you've got 7 schools and a board office sharing an Internet connection, and you need a new firewall, it's only seven-eighths eligible (unless you use a different cost allocation method).

The SECA letter makes a number of good points, but it left out 2 compelling examples of complexity: consortia and changes.  (I mentioned these issues back in 2014, when the C2 budgets first appeared.)  Since SECA has a bunch of statewide networks in it, it's surprising that it didn't highlight how difficult this will make life for large consortia.  Suddenly a consortium has to keep track of all its members' NIFs in order to know how much it needs to cost-allocate out of any new shared equipment purchase.

The changes problem is this: if a district adds a NIF to its WAN, that retroactively changes the eligibility of all shared equipment.  So if a district bought a firewall to cover its 7 schools last year, and next year decides to move the board office into its own building, suddenly that firewall is only seven-eighths eligible, so the district should self-COMAD and self-RIDF.

What really sets my teeth on edge?  In paragraph 51, the Commission says that they're not changing the rules.  Then on page 29, they change the rules.  The rules didn't used to say: "When applying for category two support for eligible services to a non-instructional school building or library administrative building, the applicant shall deduct the cost of the non-instructional building’s use of the category two services or equipment."  Now that is in the rules.