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.