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Wednesday, January 22, 2020

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.

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