Ex parte part 2

The American Library Association (ALA) dropped a delightful post-reply comment proposing changes to the E-Rate. Let's take a look. The changes suggested:

1.  Create a bid threshold where competitive bidding obligations don't apply to any purchase of less than $10,000.
2.  Eliminate the 486.
3. Permit service substitution.
4. Validate the discount every five years. 
5. Permit rolling applications for C2.

All really good suggestions. But of course I'm going to offer more fullsome opinions. 

1. Of course, I'd rather the FCC just butted out of regulating the purchasing decisions of local government entities, but this is a great first step. Honestly, $10,000 seems a little low (I like $15,000), but it would still exempt a *lot* of E-Rate purchases, especially for smaller applicants.
2. The 486 doesn't trap as many applicants as it used to, but still, eliminating a whole form would be great, and there's really no need for it. Delete! Delete! Delete!
3. This one puzzled me, since service substitutions are already permitted, but what the ALA is saying is that service substitutions should not go through a compliance review. Hell, yes! No need to hold up a ServSub. While we're at it, can we simplify ServSubs? The EPC form is a complete drag. Basically, FRN line items suck, and their suckitude is laid bare in the ServSub process.
4. Another good one, especially for libraries, who don't know what's coming discount-wise, since it's determined by their school district. Set the discount when the C2 budget is set, and let applicants change it during the 5 years if they want, like with C2 budgets now.
5. The dime has almost dropped. Yes, C2 applications should be allowed on a rolling basis. But so should C1 applications. Since we're never anywhere close to hitting the program cap, there is no need for an application window. Rolling applications for everything! Or at least multiple filing windows until the money runs out.

Bravo, ALA! Imagine this: if changes 1 and 2 happened, and the applicant chose to use the SPI method, the E-Rate application process would be one form for most purchases. You know, like a normal program, where you just file an application.

Simplify! Simplify! Simplify!