Not seeing the streamlining

For my final post on the new NPRMaFNPRM, I'll shoot my mouth off about the "Further Streamlining E-Rate Administration" section.

Use of Existing Contracts:  Oh no, don't take the Kalamazoo Reconsideration Order. Not only was it useful, it was fun to say. "What?! Another client who forgot to mention to us that they were signing a new ISP contract? Oh well, let's hope we can Kalamazoo that baby." (We could only hope that Kalamazooing would work because there was always the risk that the contract would not be the most cost-effective bid.)

But really, it's not terrible. Instead of going through the bidding treating the new contract as a bid, we'll have to go through the bidding process and ask the existing vendor to bid. On the plus side, we can make the new contract start July 1, so we won't run into this problem again.

It's hardly streamlining the process, though.

Service Substitutions: New requirements for applicants and USAC. How is this streamlining?

June 30th Deadline for SPAC Form:  Oh, no. A lot of (most?) applicants file one BEAR per funding year, and since you can't file the BEAR until the final invoice is paid, that BEAR gets filed in July or August (later if the AP clerk drags their feet on collecting the invoices). And the filing of the BEAR is when applicants discover that the SPAC has not been filed. If the deadline to file the SPAC is set at June 30th, there will be BEARs that can't be paid. That seems unfair: the service provider fails to timely file the SPAC, and the applicant gets punished. And how will setting a deadline encourage service providers to file timely? Having had to beg for the SPAC, I can say that some service providers have a very lackadaisical attitude towards the SPAC. Can we set up some punishment for service providers that fail to file by the deadline? How about this: the FCC fines them double the amount of any BEARs submitted, and then uses half the fine to make applicants whole. Of course, the applicant would then have to find a new service provider, because that provider would leave the program right quick.

FCC Form 479 Revisions:  OK, seems reasonable. But don't require that consortium members file online. Leave that option open, but allow consortium leads to collect them in any way they want. Adding some certifications doesn't add much administrative burden (it's not more forms or more signatures, just more certifications to check).

Other Form Revisions: The changes seem fine. I don't see how it's streamlining anything, though.

Cost-Effectiveness Requirements: Nope. I don't see how "the recently adopted competitive bidding portal will assist the Commission and USAC in providing transparency into whether there are patterns or characteristics of entities that receive one or no bids." I can tell you what characteristics are common to applicants that get one or no bids: they are generally 1) small and 2) remote. And if necessary, I could prove that using data already in OpenData.

The ideas for ensuring cost-effectiveness are terrible. If the FCC investigates the pricing of a service provider, that provider is more likely to withdraw their bid than go through an investigation. And if the FCC tries to apply pricing from one remote area to another remote area, the provider will withdraw their bid. And if the FCC tries to apply pricing from one client to another client who may not be the same size or the same distance from a NOC (or, for MIBS, from the engineers' home base), the provider will withdraw their bid. And none of these suggestions streamline anything.

You know what would work for Internet access at least? Reclassify Internet access as a Title II telecommunications service. Then you can regulate the hell out of the price. Otherwise, no amount of FCC interference is going to create a fair market for small remote applicants.

I really didn't see much streamlining in there. How about just calling this section "Further Changing E-Rate Administration"?