A Tale of Two Errors

It was the best of orders, it was the worst of orders.

Let's start with the name. The best of names: the "E-Rate Correction Deadline Order." Excellent! The FCC's setting a deadline to correct this mess. Wait a minute, it's spelled "Erate Correction." "Erate"?! Not capitalizing the "R" is wrong, but dropping the hyphen is a sin.

The order itself starts out the best of orders: USAC is instructed to allow corrections until the FCDL is issued, even it that's longer than 15 days. Bishop Perry Everlasting! Excellent!

Or is it the worst of orders? The FCC makes it clear that the extended response time is only for "truly ministerial and clerical errors." Uh oh. "Such errors include only the kinds of errors that a typist might make when entering data from one list to another, such as mistyping a number, using the wrong name or phone number, failing to enter an item from the source list onto the application, or making an arithmetic error." Did Bishop Perry just get gutted? Up to this point, USAC has been letting applicants correct errors without paying too much attention to the meaning of "ministerial." I'm afraid that this order is going to make them pay attention to whether the error is "truly" clerical.

But at least the FCC now has extended time to correct the spelling of "E-Rate" in the name of this order.

2-in-5 is 0-7

Another year, another demand estimate.

First, the obligatory 2-in-5 Rule rant. For the 7th straight year, the 2-in-5 Rule has failed. Priority 1 requests plus the Priority 2 requests from 90% applicants come to 3.2 billion. (Could this be the year that the FCC can't find enough money to fund Priority 2 for 90% applicants?) Internal Connections requests from 80%-90% applicants are up 18% from last year. I'm tired of beating this dead horse, but I'll keep it up until they haul it off to the glue factory. The 2-in-5 Rule must go.

Speaking of horrible rules, look at the result of the new ineligibility of "unbundled warranties": a 20% jump in Basic Maintenance requests by 90% applicants. Not to worry: many applicants still have no idea that their SMARTnet and PBX service contracts are no longer eligible, and they won't know how to cost-allocate when PIA smacks them, so look for denials to skyrocket.

Other observations:

Internet access requests are up about 17%, while telecom requests are only up about 3%. I'm guessing it's dark fiber and the loosening of Web hosting rules.

After a 77% drop last year, this year we see a further 65% drop in Internal Connections requests from applicants with a discount of less than 60%. The message is finally getting through: if your discount is less than 80%, the Priority 2 gravy train does not stop at your station, so there is no point in waiting on the platform.

For those of you tired of hearing me complain about the spelling of "E-Rate," you'd better skip today's gripe.

Has anyone else noticed that PIA reviewers are spelling it "ERate"? I think the Subject line of every PIA request I've received so far this year includes "ERate." While I applaud the capitalization of the "R," the lack of hyphen is a greater sin than a small "r."

The home front of the browser wars

OK, first I have to say that the online tools are working pretty well this filing system. My sense is that the MTBC (Mean Time Between Crashes) is about 25 clicks this year, where in most years past, it's been closer to 10. And I haven't noticed any outages. It does seem that idle pages are the devil's workshop; leaving a page alone for several minutes usually seems to bring on a crash.

The system seems speedier, but I think that's because of a browser change.

See, my teenage son finds Internet Explorer to be a worthless pile of bits, and has insisted that I use Google's Chrome browser. Don't tell him I said so, but I think the kid is right. Chrome feels faster, especially on USAC forms.

One of the reasons it feels faster is because some of USAC's "features" don't work with Chrome. You know that little pop-up that appears every time you enter a 470 number, telling you about the 470 you entered? OK, the first time it can be useful (though it still comes across know-it-allish), but with each subsequent FRN on a 471, I feel an increasing urge to strangle something. Well, with Chrome, that pop-up doesn't appear.

Using Chrome as my primary browser and Firefox as a secondary browser has given me a new appreciation of how hard it is to design Web pages to work cross-browser. Best example: with Firefox v3.6, the Apply Online page looks fine. But upgrade to Firefox v4.0, and it looks like someone kicked over those nice stacks of buttons.

Some of you are thinking: "Secondary browser?" Come, grasshopper, let me explain the horrors of the "session." See, USAC's online tools use "sessions." Basically, the Web server remembers who you are and what you're doing. Which is great, except if you're doing two things at once, you create two sessions, and they can crash into each other in unpleasant ways. Data gets corrupted, applications crash, etc. However, if you use 2 different browsers, the Web server manages to keep your sessions separate. So if I'm doing a 471 using Chrome, and I need to look at last year's 471, I open Firefox. Then if I need to Submit a Question at the same time, I'm forced to open Internet Explorer. (Don't tell my son, OK?)

Over-extended

Regular readers know that I'm a bit obsessive when it comes to terminology: the BEN mess, the meaning of RFP, the proper capitalization of E-Rate, and on and on.

But words do matter, and the latest USAC News Brief creates a mess by misusing the word "extension." USAC's problem is that they want to know how many lines an applicant has, and apparently some applicants were reporting the number of billed account numbers. So they asked applicants to give them the number of lines, not the number of accounts. OK, that's fine, but they referred to those lines as "extensions." That won't cause confusions for most applicants without a phone system, since they are paying for a phone line for each extension.

But applicants with a phone system are going to start sending the wrong info. In a phone system (from a little key system to a big PBX), there is a distinction between "lines" and "extensions."
When someone says "lines" they mean "external lines," the lines that you're paying the phone company for. "Extensions" is the number of phones connected to the phone system. So a dinky key system might have 4 lines and 16 extensions. A PBX might have 46 lines (coming in on two PRI circuits) and 500 extensions.

USAC says, "Be sure to include those lines and extensions in your line count." Which makes it sound like the owner of the key system should report 20 lines (4 external lines and 16 extensions), and the PBX owner should report 546 lines. Those numbers are adding together apples and oranges, and do not give a clear picture of usage.

Precise wording matters, and USAC should clarify that they want to know about all the lines that appear on a phone bill, but do not want internal extensions included in line counts.

Christmas in March

Hey, I stumbled across a Christmas list I made in 2006, and thought it would be fun to go back and see which wishes have been granted over the last 4 years.

Granted:

1. New online Form 486
2. "Two-signature/two-date" finally put to rest
3. Registration of consultants
4. Dark fiber eligible
5. The same PIA reviewer 2 years in a row (it does happen sometimes)

On #3, I kind of feel like, "Be careful what you wish for." The FCC has registered consultants, but it hasn't done anything to drive out the quacks, which is what I was hoping for. But there is hope: E-mpa® is beginning self-regulation of the consultants, which should work out better than any FCC attempt to regulate the industry.

Not granted:

1. COMADs only for Waste, Fraud, Abuse, not errors
2. No Form 486
3. All FCC appeals decided within 90 days
4. Publish the secret 700-page PIA manual
5. How about publishing 200 pages of it?
6. How about just telling us what triggers a Cost Effectiveness Review?
7. Don't take the Data Request Tool offline at night
8. At least let us know when the DRT will be offline
9. At the very least, let us know that the DRT is offline. As it stands now, you just get a message that no records were found.
10. A "copy" button on the 470 and 471 which lets you import all the info from last year's forms [For most small, low-discount applicants, those forms are identical year in and year out, and for all applicants, many elements are identical.]
11. Let applicants edit BEARs after they've been sent to service providers, so we can correct errors the service providers find
12. An online tech plan tool that applicants can use, set up so that it will generate plans that the SLD won't later decide are inadequate
13. A list describing the most outrageous requests. You know that PIA reviewers must pass around really hilarious requests. Let us all in on the joke.
14. Block 4 information in the Data Retrieval Tool
15. The discount matrix topping out at 80% for equipment
16. An "about us" page for the SLD. There aren't that many people there, and I'd just love to see a brief resume for each of them.
17. Mel Blackwell in a red suit and beard, flying all over the country, handing out Priority Two funding to applicants with a 40% discount. Ho ho ho.

A lot of my unfulfilled wishes have to do with the online tools. Mel promised to fix at least some of them, but he did say that was dependent on getting a new IT infrastructure, and I gather we're all still waiting for the FCC to approve funding for that.

It's a wrap

I believe the 470 filing season is over for me. It would have been over sooner, but I got a call at 3:00 p.m. from a school: "Can you do our E-Rate for us?" How could I refuse? Now I think I'll go home before anyone else calls.

It also would have been over sooner if the 470 application hadn't gotten so buggy at the end there. I was averaging 3 crashes per form.

And of course, it would have been over a *lot* sooner if a few clients weren't such procrastinators.

Anyway, in honor of the close of the window, I have a fun "Stupid 470 Trick" for you. It's not a bug per se, since you have to do something verboten to make it happen, but it is kind of amusing.

OK, so here goes:

1. Create a 470 (oh, go ahead, as long as you don't hit "Submit" at the end, it doesn't count).
2. In that page after you get your 470 number, check the boxes to put in Telecom and Internet services (any two categories will probably work, but we'll use these).
3. Put some telecom services in Item 8.
4. Click the "Next>>" button to move to Item 9.
5. Put in and Internet service or two.
6. Use the browser's "Back" button to move back to Item 8. (Do not use the "Previous" button at the bottom of the form. Since you're never supposed to use the "Back" button, this step makes this process a parlor trick, not a bug.)
7. Put one more telecom service in Item 8.
8. Use the "Next>>" button to move back to Item 9.
9. Note that all the telecom services you had put in Item 8 have now overwritten the Internet services you had written in Item 9.

Sure, it's a cool trick to amaze your friends with, but I can tell you, I didn't think it was so cool when I discovered it by accident.

I have not done cross-browser testing, but I'll bet it works no matter what browser you're using. Also, I'll bet you can skip step 7, but I didn't test that, either.