Side rant

 Word from USAC:

A recent change by Microsoft prevented users with Outlook from receiving some email notifications from EPC between July 30 to August 5, 2025. USAC recommends users check their news feed to monitor any FCC Form 471, post commitment, and FCC Form 486 notifications that may have been missed.

Now you might think I'd rant about the email outage, but I don't fault USAC for that; they found the problem and fixed.

No, I'm going to rant about the recommendation to "check their news feed." To which I say: which news feed? 

As a consultant, I have news feeds for:

1. Myself as an individual
2. My company
3. Each of my clients 
4. Each consortium to which my clients belong 
5. Each of my clients' individual 470, 471 and 486 forms
6. Each FRN on each of my clients' 471s
7. Each FRN line item on each of my clients' 471s

There may be some others I'm not thinking of. 

Some notifications make sense: RNLs, RALs and FCDLs appear in the news feeds for both the organization and the relevant form. But why don't FCDLs appear in the feed for each FRN? Nothing seems to appear in the FRN and FRN line item news feeds, so why do they exist?

But RFCDLs do not appear in the news feed of the form(s) to which they pertain, only in the organization's feed. Appeals, too.

In the case of a consortium, the notifications appear in the consortium's news feed, but not in the feeds of the organizations which belong to the consortium.

You know what I use news feeds for? Absolutely nothing. If an email gets lost, we'll pick up whatever the notification was about in some other way. 

Well, they did ask

 Want to give Congress a piece of your mind about the E-Rate program? Now's your chance.

The Congressional Universal Service Fund (USF) Working Group has put up a form to submit comments. (You can also email comments to USFWorkingGroup@fischer.senate.gov.) The questions are pretty wide open, so you can let Congress know how you feel on any USF-related topics.

For me, nothing springs to mind for the questions in the Effectiveness section, but the Reforms section has my mind whirring.

The first question:

What reforms within the four existing USF programs would most improve their:
- Transparency;
- Accountability;
-Cost-effectiveness;
- Administration; and 
- Role supporting universal service?

Transparency: How about making public the 700-page book of procedures for handling applications?

Cost-effectiveness: Cut the top discount rate to 65%.

Administration: Stop making applicants go out to bid for $1,000-a-month Internet. Wait, what am I saying? Get the FCC entirely out of the business of regulating the purchasing practices of local government entities.

Role supporting universal service: Triple the C2 budget for applicants. The current level is completely inadequate.

Second question:

 What reforms would ensure that the USF contribution factor is sufficient to preserve universal service?

Expand the revenue base; most of the increase in the contribution factor is due to a decrease in the contribution base. ISPs are the main beneficiaries of the E-Rate program, so they should be paying into it. I mean, voice service isn't even eligible any more, so why should voice service alone pay into the fund? Let's toss in big edge providers, too, who benefit mightily from school children learning to use the Internet.

 

Third question:

What reforms would reduce waste, fraud, and abuse in each of the four USF programs? 

Looking just at the E-Rate, getting the FCC out of regulating purchasing would help cut waste by allowing schools to have service providers suggest configurations before going out to bid; applicants could choose the most cost-effective configuration, not just the only configuration they happen to know of.  I think requiring electronic deposits for reimbursements has made fraud much more challenging. To cut fraud further, require that applicants use an E-Rate management professional; since E-Rate is all we do, we can spot shady deals, and since our entire livelihood is the E-Rate, we steer well clear of fraud. To cut abuse (and waste), cut the top discount to 65%.

Fourth question:

What actions would improve coordination and efficiency among USF programs and other FCC programs, as well as broadband programs housed at other federal agencies? 

Oh no, don't tell me overbuilding is going to come up in Congress, too. Seriously, I can't think of any efficiencies to be gained by coordinating the E-Rate with the other USF programs. 

Sixth question (I skipped #5):

Is the USF administrator, the Universal Service Administrative Company (USAC), sufficiently accountable and transparent? Is USAC’s role in need of reform? 

According to the FCC's response when I made a FOIA request, USAC's routine processing of applications is a law enforcement action, so their procedures are secret. Make those procedures public.

That's enough ranting for now. 

No goooooooooal

The FCC just released a new report setting speed standards for broadband to be considered "advanced telecommunications."

Of course, I skipped to paragraph 14, "Schools and Classrooms." They plan to keep the status quo, which is a short-term goal of 1 Gbps per 1,000 students, and no long-term goal. That short-term goal seems fine to me, but I think we should have a long-term goal. Long-term goals are important in generating long-term progress.

And the reason for not having a long-term goal is, in my view, spurious. They claim that the goal of 1 Gbps down / 500 Mbps up would not be technology-neutral (in particular, excluding wireless and satellite technologies).  It's true that wireless and satellite are not currently able to meet the upstream speed of 500 Mbps, but that doesn't mean the standard is not technology-neutral. You know what other technologies can't make that speed? DSL and ISDN (T-1s). Should we restrain the goals so that we don't leave those technologies behind? No. We push for higher speeds, and as some technologies prove unable to scale, they fall by the wayside. If wireless and satellite can't keep up with future needs, then we'll cease to use them.

How to set the long-term goal? I'd start by looking at how the short-term goal has evolved. I haven't looked at the data, but my guess is that we'll be multiplying bandwidth use 10 times over the course of 5 to 7 years. So let's say the long-term goal is 10 Gbps per 1,000 students by 2032. That goal is completely guesswork, but you know what? It's better than no goal.

Delete! Delete! Delete! Delete! Delete! Delete! Delete! Delete! Delete! Delete! Delete!

 The first order from the "Delete! Delete! Delete!" docket was just passed by the FCC. According to the press release, the order removed "11 outdated and useless rule provisions—covering 39 regulatory burdens, 7,194 words, and 16 pages." The rules covered  things like "telegraph, rabbit-ear broadcast receivers, and telephone booths."

Who wouldn't agree to that? Well, Commissioner Gomez, for one. The lone Democratic commissioner voted no. Why? Was this just "the Republicans are for, so I'm against it"? Not according to Commissioner Gomez's statement. Her concern is procedural. She wants each rule to be published as an NPRM (which maybe they should call an "NPRD!D!D!") before any changes are voted on.

I have to agree. I was thinking about my own suggestions for D!D!D!, and I thought, "I hope they ask for more comment before they take any of my suggestions." Because I'm brilliant and all, but even I can't think of every possible consequence of a rule change. That kind of thing needs crowdsourcing. 

In this case, it sounds like the Commission went after truly obsolete rules, but I hope that in the future, they'll ask for comment on any changes they're planning to make, because even in obsolete rules, there may be some line that is important to a current service. 

Cap karma

Look who's getting a cap now. FCC Chair Carr had requested a $26 million dollar raise for the FCC, but the House said: "No, you'll get $390.2 million and like it." Just like last year and the year before.

This doesn't affect E-Rate funding directly; the Universal Service Fund is separate. But it does mean the FCC won't have any more people to work on the E-Rate. Which, depending on your level of pessimism or optimism, might have meant the FCC making more rules for the E-Rate or might have meant faster processing of thorny appeals.

New pronunciation

Watch tonight's Late Show with Steven Colbert. He gives us a new way to pronounce "FCC." Hint: it will be bleeped out.

Lots of waiving lately

 While I'm dusting off old tables, here's one I did for a few years looking at whether the FCC abided by their own rule from the Third Report and Order (paragraph 40), that the Eligible Services List (ESL) must come out at least 60 days prior to the opening of the filing window. Here's the table: 

FY	ESL release	Window open	60 days?	Window close	Window days
2025	10/25/2024	1/15/2025	82	3/26/2025	70
2024	12/18/2023	1/17/2024	30	3/27/2024	70
2023	12/14/2022	1/18/2023	35	3/28/2023	69
2022	12/17/2021	1/12/2022	26	3/22/2022	69
2021	11/30/2020	1/15/2021	46	3/25/2021	69
2020	12/9/2019	1/15/2020	37	3/25/2020	70
2019	11/15/2018	1/16/2019	62	3/27/2019	70
2018	10/5/2017	1/11/2018	98	3/22/2018	70
2017	9/12/2016	2/27/2017	168	5/11/2017	73
2016	9/11/2015	2/3/2016	145	4/29/2016	86
2015	10/28/2014	1/14/2015	78	3/26/2015	71
2014	10/22/2013	1/9/2014	79	3/26/2014	76
2013	9/27/2012	12/12/2012	76	3/14/2013	92
2012	9/28/2011	1/9/2012	103	3/20/2012	71
2011	12/6/2010	1/11/2011	36	3/24/2011	72
2010	12/2/2009	12/3/2009	1	2/11/2010	70
2009	11/21/2008	12/2/2008	11	2/12/2009	72
2008	10/19/2007	11/7/2007	19	2/7/2008	92
2007	10/19/2006	11/14/2006	26	2/7/2007	85
2006	11/22/2005	12/6/2005	14	2/16/2006	72
2005	10/14/2004	12/14/2004	61	2/17/2005	65

 Looks like after a good run from 2012 to 2019 (after a very bad run from 2006 to 2011), the FCC has had to waive their own rule repeatedly, until this year. Let's hope they return to keeping it at least 60 days.

Why does it matter? Well, until the ESL comes out, we don't know what products and services the E-Rate will fund, at least in theory. If we don't know what's eligible, how can we start discussing what goes on the Form 470, which I should think the FCC would like us to file before the opening of the window; early filing makes everybody happy. I say "in theory" because in practice, the FCC rarely makes any changes in eligibility from year to year, and generally doesn't make any changes from the draft ESL, released weeks earlier, and the final ESL.

At least the length of the filing window has remained steady of late, and gives applicants plenty of time to file a Form 470, wait the required 28 days, and file a Form 471, because a lot of applicants plan to file both forms within the filing window.