Between the acting of a dreadful thing and the first motion, all the interim is like a phantasma

Frankly, the departure of Scott Barash, USAC's CEO, wouldn't have warranted a blog post, but one statement in the press release caught my eye: "served as Acting CEO since January 2006."  That's right, for most of USAC's existence, Barash has been acting CEO.  Thinking of him waiting 8 years for someone to make a decision makes me feel better about the speed of the appeals I have sitting at the FCC.

The press release says we'll now have an "interim" CEO.  Maybe after a few years, they'll upgrade her/him to "acting."

Webhost warpath

At least it's better than soliciting spamments.  One web hosting company just sent out an email to customers with a handy online form for adding yourself to their letter asking the FCC to keep Web hosting as a Priority One service.

One statement in the email caught my eye: "...thousands of school districts from across the United States submitted comments on the proposed E-rate funding changes...."  Thousands?!  That seemed a bit high, so I checked: there are only 1,513 comments filed in Docket 13-184.  And a lot of those are not from applicants.  I would bet there are fewer than 1,000 comments from school districts.

I said long ago that I think web hosting is overpriced, but since it eats up less than 2% of the fund, it's not worth a lot of my time.

MiConcern

Another year another E-Rate Survival Guide from E-SchoolNews.  (I know they'd like it spelled eSchoolNews, but as I promised, if they're going to pervert the name of our beloved program to "eRate," I will make my own changes to their name.)

I wouldn't say it's really a survival guide.  More of a "State of the Program."  But it has good information, and finishes with the suggestion that applicants should hire a consultant, and of course I'm behind that.

Since Mitel sponsored the guide, it's no surprise that it includes a suggestion that given the current funding shortage is to shift costs to Priority One by purchasing hosted voice services like, say, Mitel's MiCloud VoIP service.

That's pretty good advice for many applicants, and hosted VoIP is the way a lot of applicants are going, especially smaller ones.  But there is one niggling worry in the back of my mind.

Change is coming to the E-Rate.  It is likely that by Funding Year 2015-2016, the program will be focused on increasing the bandwidth to schools.  One of the ways that the FCC is considering to find more funding for bandwidth is to kick some outmoded services out of the program.  For example, it looks like pagers' days are numbered.  The problem is, if you only throw out completely outmoded services, you only save a tiny amount of money, since no one is using those services (kind of the definition of "outmoded").  If the FCC wants to really save money, they're going to have to toss out popular services.  One of the suggestions has been to throw voice services out of the program, or at least move it to a lower priority.  The comments of the commissioners make it sound like they want to keep VoIP and toss out traditional voice, but it's hard to see how they do that in a technologically neutral way.

If the FCC does kick voice out, they may phase it out.  (That doesn't solve the funding crunch, but it would be a typical political move to modify a reform to make it more palatable, which makes the reform ineffective.)  But there is a chance that they won't make the change gradually, especially if they're just demoting voice to a lower priority.  The Commission has been known to make rule changes retroactively.

So there is an outside chance that the FCC will change the eligibility of voice, lump VoIP in there, and make the change happen instantly. In that case, it's possible that hosted voice plans won't be funded in 2015-2016.  If you move to hosted voice in 2014-2015, you're almost certainly signing a contract for at least 3 years.  So there is some chance that you won't have E-Rate funding for years 2 and 3 of that contract.

I guess what I'm saying is that it's a bad time to count on E-Rate funding for a multi-year contract, unless maybe it's for bandwidth.

Fire your consultant, hire a psychic

Warning: pointlessly snarky post.

Am I the only one who noticed that this week's SL News Brief, describing the new Form 500 included the sentence:
"Applicants can no longer submit these requests and notifications by email, fax, or on paper."

Since there is no online version, I guess you need to submit your Form 500 telepathically.

Hard of hearing

I got a little behind over the holidays, so I'm just now posting about the December 12th Congressional oversight hearings.

Two of the Commissioners, Pai and Rosenworcel, mentioned the E-Rate in their opening statements.  I didn't see anything new their statements, so if you're interested in what I think of what they said, just check out earlier posts on Pai and Rosenworcel and the NPRM.

I listened to the hearing while working, so I can't promise I heard every significant thing that was said about E-Rate, but here is what jumped out at me.

One of the congresspeople asked Chairman Wheeler about the E-Rate.  His response:  “On E-Rate, … there is a leader on this Commission….  I would like to associate myself with the remarks of Commissioner Rosenworcel.”  Well, that certainly makes me think that we're going to see implementation of Commissioner Rosenworcel's ideas.

When asked when we'll see reform, Commissioner Wheeler said: “We are going to put out a schedule … to address this issue.”  How about giving us a schedule on when you're going to put out that schedule?
When asked what Congress could do to improve the program, Commissioner Rosenworcel said: “I think we can do more with the program just as it is.” There was a lost opportunity.  I guess if I were a Commissioner, I'd stick close to the "just leave us alone" line, too, but there are some things that Congress could do.  How about scrapping CIPA, for example?

Here are some other statements from Commissioner Rosenworcel, along with my comments:

• “[W]e do subsidize a whole bunch of old-fashioned services right now.  We should phase those out over time, and focus instead on capacity and bandwidth.”  Another clear indication that E-Rate is going to become about Internet, not telecommunications.  I'm pleased to see "over time" in there; I was afraid applicants would be whipsawed by sudden changes in the ESL for 2015-2016.
• “[W]e need to reduce bureaucracy.  Bureaucracy gets in the way of small and often rural schools….”  Bureaucracy gets in the way of every applicant.  It's more obvious for small applicants because they can't justify hiring staff or a consultant for the paltry funding they get.  Rurality is irrelevant.  I'm all for reducing bureaucracy.  Who isn't?  "Bureaucracy" is second only to "terrorism" in provoking antipathy.  But let's be clear: the way to reduce bureaucracy is to reduce the number of rules, and make all the rules public.  Bureaucracy is not reduced by carving out special rules for small applicants or consortia or rural applicants or fiber or VoIP or whatever.
• “I’d like to see us encourage greater use of consortia to improve bulk buying power, and also have multi-year applications to reduce the administrative burden….”  Ugh, again with the consortia.  Consortia don't always lead to lower prices.  Consortium purchasing benefits large service providers more than small applicants.

Commissioner Pai didn't get as much time, but he did get to answer one question.

Rep. Pompeo: “Who is responsible for policing to make sure the E-Rate program is being used appropriately..?
Comm. Pai: “In theory, the Universal Service Administrative Company, as overseen by us, monitors, [the program], but in practice, given the limited resources at USAC and given the limited resources the FCC has to oversee USAC, there is not a great deal transparency and accountability in the system.”

The lack of transparency has nothing to do with lack of resources.  In fact, the FCC and USAC expend resources keeping the system opaque.  The lack of transparency in this program is the result of an attitude at the FCC and USAC that if local government officials are given information, they will use it to defraud the program.

Rep. Pompeo voiced concerns about a ne'er-do-well service provider now operating under a different name and expanding its use of government funding in Colorado.  He didn't mention a name, so I had to do some digging.  I think I found what he was talking about in a Denver Post article.  It seems that a Colorado fiber network funded by federal BTOP tax dollars is being turned over to Affiniti, the successor to the bankrupt Trillion.  If you're not familiar with Trillion, here is a good summary of their fate.  Apparently, Affiniti is also taking over a BTOP-funded network in Florida.  It does seem unsavory that networks built with tax dollars are being turned over to a private company, but the other way to look at it is that Affiniti bought assets from Trillion after their federal funding unexpectedly dried up (due to E-Rate investigations), and is now taking over from other federal funding recipients who ran out of money.

Perhaps instead of complaining about the company that's taking over these assets, we should take a look at the advisability of using federal funds to build fiber networks.  Oh dear, did I just call into question the wisdom of the FCC's proposed course change for the E-Rate?  And so soon after Christmas, too.  Well, hopefully I can work myself off the naughty list by next December.

Bah! Humbug!

You say "Christmas cheer," I say "spam"; let's call the whole thing off.

I'm a bit ambivalent about holiday cards from corporations.  I'm all for spreading as much holiday cheer as possible, but it's weird for me to have an organization I'm doing business with send me a card, because it tends to further blurs the line between what is real human caring and what is cynical marketing.  I wish all my customers and suppliers and colleagues a joyous holiday season, but my company does not.  Like all corporations, On-Tech exists to make money.  So every year I'm tempted to send out cards to business contacts, but I never do.

But here is a case about which I am not ambivalent: a telecom carrier (who shall remain nameless) sent a Happy Holidays email to every contact email address on FY 2014-2015 Forms 470.  And just to add that personal touch, the email is from "no-reply."  Really?  A holiday greeting sent by a mailbot to people you've never had contact with except an email bid?

What a holiday cheer buzzkill.  I think I'll have to knock off early this afternoon and take the kids to a movie, to see if my Christmas mood can be restored by Smaug.

What would Bishop Perry say?

From a recent PIA request:
Please address the questions listed in the attached reminder letter regarding FY2013 E-rate Application #....  Your response is due 12/25/2013.

Somebody's getting coal in her stocking this year.