Get your comments in now

 We've got new deadlines for comments to the draft ESL. Originally, comments were due on October 15, with reply comments due October 30.  Today the FCC announced what the new deadlines would be for all the deadlines that fell during the shutdown. There's no mention of the Eligible Services List, so this sentence applies: "Filings that were due between October 1, 2025 and November 17, 2025, inclusive, are now due by November 18, 2025...."  The reply comments? "...if comments in a rulemaking proceeding were originally due on October 15 and reply comments were due fifteen days later, comments are now due on November 18, as set forth above, and reply comments are due fifteen days thereafter on December 3."

I think it's worth commenting on MIBS and cybersecurity, if not to make a change this year, then to put a bug in the FCC's ear for the future. And if you'd like to express your frustration at the sudden revocation of funding for hotspots and bus Wi-Fi, here's your chance. 

High-fiber diet

 Funds for Learning' annual E-Rate Trends report it out. (Get your copy here). It's full of interesting data from their annual survey of E-Rate applicants, and best of all, the data is presented in graphs, and I do like my data in pictures.

The only thing that really jumped out at me was this graph:

 

I wasn't too surprised to see that about two-thirds of equipment purchases were access points and switches. Firewalls and UPSes might make up a bigger portion, but they almost always have to be cost-allocated, so I advise clients not to apply for those, since they're going to use up their whole C2 budget on access points and switches.

I was a little surprised to see that about two-thirds of broadband comes over fiber. That's certainly true for my clients, but I thought some less-developed areas would be using more copper or wireless. I'm glad to see that fiber is so widespread. 

I wonder, though, if instead of looking at dollar amounts, the graph looked at the number of connections, whether the proportion would change. Because around here, the typical 100 Mbps over cable (copper) is around $100, while the the typical 1 Gbps over copper is $1,000, so if you had the same number of each type of connection and looked at the dollar amounts for each type, it would look like fiber was ten times as common. Well, no graph is perfect.

 Still, it's an interesting graph, and the rest of the graphs are worth looking at. 

Thankful for small mercies

 Not many silver linings to the dark cloud that is the government shutdown, but here's one: you know that case that went to the Supreme Court trying to end the USF, which includes the E-Rate? Consumers' Research v. FCC. Well, it's been relaunched. And this week the Fifth Circuit granted the FCC's petition to pause the case because of the shutdown. So the longer the shutdown persists, the longer the USF is safe. (I don't think the case is much of a threat to the USF, but still....

LCP FTW

Well, lookie: Lowest Corresponding Price (LCP) is raising its head again. It had a brief heyday last decade, but then seemed to go back into the background. But now a whistleblower lawsuit started ten years ago may actually be going to trial. Someone did an analysis of what AT&T was charging schools, and discovered that they were not giving schools the LCP, and filed suit. The suit's already been to the Supreme Court and back, and now it looks like it may get to trial on January 20.

Under the hood of the revenue base

So Anchornets has got me thinking about the USF contribution methodology. I've already posted about how the increase in the Contribution Factor (38.1% currently) is due more to a shrinking revenue base than to increases in program expenditures (and the expenditure increases are mostly over at the High Cost program).

But it got me thinking about how the revenue base is calculated, so I thought I'd look into it. Is the information useful? I don't see how unless you work for a carrier, USAC or the FCC. Is it interesting? If your answer is yes, you are too far down the USF rabbit hole.

The revenue base comes to USAC via the 499-Q, by which carriers report their interstate and international long distance revenue. (The USF fee is only charged on interstate and international revenue.)

But where do the carriers get the number from? It's not like the old days, when your phone bill listed each long distance call and the amount you paid for it. That was the norm in 1996 when the E-Rate was being created. Telecom people call those lists call detail records (CDRs). In those days, carriers could just add up all their interstate and international call revenue, since they were keeping track of each call.

But that's not an option for most modern carriers, so they have two options: 1) a traffic study or 2) the "safe harbor." 

The traffic study is what it sounds like: the carrier randomly selects a set of calls and then determines what percentage are long distance. So a wireless provider might find that 25% of their users' calls are interstate or international, so their percentage of interstate usage (PIU); they can multiply their total revenue by 25% to come up with their revenue base for the USF.

The safe harbor is a percentage that the FCC sets for carriers who can't or don't want to do a traffic study. It was last set in the 2006 Contribution Methodology Reform Order, which set the safe harbor at 37.1% for cell phones (paragraph 2) and 64.9% for VoIP (paragraph 53). (For those keeping score at home, it left the safe harbor for pagers at 12% and for analog SMR dispatch (whatever the hell that is) at 1%.) So a cell phone provider too lazy to do a traffic study can multiply their total revenue by 37.1% to come up with their revenue base for the USF.

What percentage of carriers are using the safe harbor percentages? I wish I could find that out. Does anyone out there know? [Why do I want that piece of data? Because it's there.]

I warned you at the beginning that this post wouldn't be useful or interesting. 

Let your geek flag fly

 Just finished SHLB's AnchorNets conference. It's a great place to geek out with other people who know the names of the FCC Commissioners, are happy to discuss the E-Rate Modernization Order, and know why Jessica Rosenworcel deserves a standing ovation.

My favorite sessions: 

1.  A discussion on the proper relationship between applicants and service providers. Not a lot of good news, and there's a lot of grey area, but the session did a good job of delineating the edges of the grey area.
2. A panel with two staffers of Senators on the USF Working Group, mostly because it seemed clear that they understand that the contribution methodology is job one. 

If that sounds like fun to you, register for AnchorNets 2026 now and get $150 off the price.