Entities on the move

I have ranted more than once about the use of the word "entity" in the E-Rate program. A November 2010 News Brief tried (but mostly failed) to explain the difference between "entity number" and "billed entity number."

I just noticed a new muddying of the water. On Item 5c of the new Form 470, applicants are asked to put the number of "eligible entities" covered by the Form 470. The instructions give examples of eligible entities, including elementary schools, bus barns, library branches, bookmobiles, ... (insert sound of record scratching here). Bookmobiles?! Does this mean bookmobiles get entity numbers? Or are there eligible entities that do not require entity numbers?

I'll say it again: the term "entity" should be struck from the E-Rate lexicon. The meaning of the word has become irreparably muddied.

90% is too close to free

I've said before on this blog that the top discount on Priority 2 should be lowered to 70%. Now I'm kind of rethinking that. Now I think maybe the discount should be lowered for Priority 1, too.

Why am I changing? Well, I've always said that the waste, fraud and abuse (WFA) caused by the 90% discount is really just in Priority 2. Now I'm not so sure. I recently saw a case where an applicant made a purchasing decision on telecommunications services that I think is wasteful, because they knew that they were going to get 90% off the cost. Now, this applicant didn't do anything wrong that I could see: they followed all the rules, and the solution they chose is not fraudulent or abusive. But I'm sure without E-Rate funding, they would have made a different decision. And I think they might have made a different decision if they'd been forced to pony up 30% of the cost, instead of just 10%.

I still think all the real WFA is in Priority 2, but for the first time I've seen how a 90% discount in Priority 1 is a problem, too.

To paraphrase a recent New York mayoral candidate: "The discount is too damned high!"

Waiving in the New Year

I sure hope the good folks over at the FCC got what they wanted for Christmas, because they certainly gave out plenty of holiday cheer. Taking a quick look at recent appeal decisions, the FCC tally since November 23rd:
Appeals granted: 69
Waivers granted: 205
Denied: 1

It's like the heady days after the Bishop Perry Order, when it seemed like the FCC would waive anything.

Another thing that jumped out at me: many decisions came within 60 days of the date the appeal was filed. The fastest I saw was one appeal in the Academia Bautista decision; the appeal was filed on 11/22/10 and decided on 12/19/10. That is breathtaking speed for the FCC. True, that decision also included appeals that were filed in 2005, but it's the holidays, so let's look on the bright side.

More ubiquitous than I thought

Well the applications for the Education Deployed Ubiquitously 2011 pilot program are in. (You can see them by going to the FCC's ECFS (Electronic Comment Filing System) Search for Filings page, type "10-222" (without quotes) into the "Proceeding Number" box and click the "Search for Comments" button.

As of this morning, there were 88 submissions. Some look like duplicates, but it still looks like over 80. So now I guess the Wireline Competition Bureau gets to spend their holidays reading through grant applications. Since earlier documents indicate they are expecting to award funding to around 10 applicants, they'll be playing Scrooge to around 70 applicants.

I'm actually surprised they got so many applications, since it's only supposed to be schools that are already giving students off-campus wireless access.

hraunfoss, we hardly knew ye

Warning, severe E-Rate geek alert. Honestly, I don't know who but me would even notice such minutiae, but I like to think that there are people who are as consumed with this stuff as I am.

Over the weekend, I noticed that I could not access any document which was stored on hraunfoss.fcc.gov. Which is a drag for me, because lots of appeals, orders, etc. were stored on that server. There are probably a couple hundred links on this site to hraunfoss. But I figured someone had kicked a power plug out of the wall on the way to happy hour, and on Monday morning would plug it back in and hope that no one had noticed.

Then I noticed that some of the documents that would have been on hraunfoss were becoming available on www.fcc.gov under a new URL pattern. Uh oh, hundreds of broken links to repair?

But today I've noticed that hraunfoss is alive again, and that it appears that the FCC has left an autoforward for documents that moved off hraunfoss, so if I use the old URL, I get to the new page. (Want to try it? Type in the URL http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-10-2360A1.pdf and look at the URL you end up at.

From a practical standpoint, it would be better for me if hraunfoss went away, since all the applications that normally detect URLs as you type them and turn them into hyperlinks automatically never seemed to understand that "hraunfoss" could be the start of a URL.

But I hope it stays around. For me, hraunfoss always conjured a lovely image of a castle in the Scottish highlands. I liked it much better than it's compatriot, fjallfoss. (Turns out they're both waterfalls in Iceland. Google translator says hraunfoss means "lava waterfall" and fjallfoss means "mountain waterfall," but they also seem to be specific waterfalls in Iceland.)

Now this is the kind of information that should be on E-mpa®'s certification exam for E-Rate consultants.

Start Your Engines!

Well, maybe at least think about kicking the tires. The filing window has been announced: January 11 to March 24.

I'm happy the window is so late.

For those keeping track, here's how the window stacks up against years past, in terms of window length and compliance with the FCC rule requiring 60 days between publication of the Eligible Services List and the opening of the window:

So the window is a typical length. The time between the publication of the ESL and the opening of the window is unusually large, and really, the ESL was announced back in September, so it's almost like the FCC followed their rule this year.

He's no Joe Barton

I'm breathing a little sigh of relief: Joe "Bleed It Dry" Barton lost in his bid to return to chairmanship of the House committee which oversees the E-Rate. Instead, we have Fred Upton, which is a good thing. I think.

First of all, he knows the E-Rate, since he has been chairman of the Telecommunications Subcommittee.

The ALA once characterized him as "very supportive of the E-rate."

The only action I can find (since his part in the 2005 call for serious reform) is sponsorship of a bill to allow schools to get E-Rate funding for emergency notifications systems. Which makes me fear that he'll join in the mission creep that I'm afraid will be the E-Rate's undoing.

Still, that's just a dark cloud on the horizon. For now, the political sun shines on our little patch of heaven.