Now it's starting to get my goat. In a recent appeal decision, the FCC denied appeals from 90% applicants who thought they should have gotten some Priority Two funding in FY 2013-2014. The FCC denied the appeal. I actually don't have a problem with that. Here's what has me frowning: "In funding year 2013, there were insufficient funds available to fund any priority two requests." Untrue. There were insufficient funds to follow the established precedent of funding applicants at a particular discount level only if there is enough funding available to fully fund all applicants at that level. But there was some funding available. According to USAC's Q2 Fund Size Projections, there were at least $600 million ready for rollover on january 31, 2013. Also, there was $250 million available in the FY 2013-2014 pot. On January 24th, Chairman Wheeler blogged that "As part of our top to bottom review of E-Rate, the opportunity has opened to use existing funds to immediately begin to expand E-Rate funding targeted to high-speed connectivity to students in schools and libraries." So on January, the FCC had $850 million available, plus whatever Chairman Wheeler wanted to leverage out of the fund. The denial of P2 requests for 90% applicants wasn't approved by the FCC until February 24th, and the first denials weren't until March 5th.
Maybe the FCC couldn't have funded the entire $1.76 billion in Priority Two requests from 90% applicants. But there is a procedure for that in 47 C.F.R. 54.507(g)(1)(iv): "If the remaining funds are not sufficient to support all of the funding requests within a particular discount level, Schools and Libraries Corporation shall divide the total amount of remaining support available by the amount of support requested within the particular discount level to produce a pro-rata factor. Schools and Libraries Corporation shall reduce the support level for each applicant within the particular discount level, by multiplying each applicant's requested amount of support by the pro-rata factor."
I have no objection to the FCC refusing to pro-rate. I think pro-rating would be a disaster. But it bothers me when they act like it was impossible for them to fund any applicants. The FCC chose not to fund any P2 requests, and had to waive its own rules to do so.
At least I won't have to complain about this in the future: as I had suggested, in the 7R&O, the FCC abolished pro-rating (see 47 C.F.R. 54.507(f)(4) on page 134).
Wednesday, July 30, 2014
Friday, July 25, 2014
It's getting wilder and wilder
It looks like the 7R&O has spawned a new beast to add to the funding process hydra, the Wi-Fi-Rate chimera and the GSA minotaur. I think I'll call it a satyr, since it's small and harmless.
A lot of NPRM commenters opined that applicants shouldn't have to file an application year after year for the same multi-year contract. The FCC heard and created another application process for multi-year applications. Oy.
I don't think I will ever use this form. Because filling out an item in Block 5 to cover a multi-year contract is quick and easy. It would be really easy if USAC built a "copy last year's 471" button.
What is required on the new form? The FCC says in paragraph 194:
A lot of NPRM commenters opined that applicants shouldn't have to file an application year after year for the same multi-year contract. The FCC heard and created another application process for multi-year applications. Oy.
I don't think I will ever use this form. Because filling out an item in Block 5 to cover a multi-year contract is quick and easy. It would be really easy if USAC built a "copy last year's 471" button.
What is required on the new form? The FCC says in paragraph 194:
- "basic information identifying the applicant": To do a Form 471, I just give the BEN and the rest autofills.
- "confirm that the funding request is a continuation of a FRN from a previous year based on a multi-year contract": You mean like the Item 15d checkbox on the Form 471?
- "identify and explain any changes in...the discount rate": You mean like editing the Block 4 that I can import from last year?
- ""identify and explain any changes in...the membership of a consortium": What?! How can a multi-year contract survive joining or quitting a consortium? Wouldn't a new contract be required?
- "identify and explain any changes in... the services ordered": You mean like filing an Item 21 Attachment?
So let's see, the new form has Block 1, Block 4 and Block 5. You know they aren't going to omit all those certifications in Block 6. And now that we have measurable goals, they're not going to give up on that Block 2 information. That's all the blocks.
For applicants who have only one FRN, and it's a multi-year contract, maybe this is a minor improvement, but for everyone else, it's a waste of time.
And as with real satyrs, innocents should beware. Because if you have a new multi-year contract, you'll think that you can use this new multi-year contract form. But no, you have to file a Form 471 in the first year, and then this new form in subsequent years. Make that mistake, and the satyr will show its frisky side and you'll be....
That doesn't look like 20% per year
Who came up with this idea of phasing out voice service by lowering the discount percentage by 20 every year? What they should have done is reduce the pre-discount amount by 20% each year. It's better in three ways:
Here's a table showing the effect for all applicants over the next 3 years. (Sorry, the 4th and 5th years won't fit.)
The "cost allocations" columns show the apparent funding effect if the 20% is taken off the pre-discount cost. I didn't have to do columns for every year, because the effect is the same every year. I didn't really have to do rows, either, since every applicant sees the same effect every year. Looks fair, doesn't it?
The other columns show the varying effect that applicants will feel as their discount percentage is cut 20%. Year 1 shows the strongest effect. Does it seem fair that applicants at the lowest discount level lose 100% of their funding? Does it seem fair that applicants at the highest discount level see a 200% increase in costs?
Why would the FCC do it? Well, the FCC is trying to cut voice costs. What I call "Funding Lost" is, from the FCC perspective, "funding moved from voice to broadband." Look at that column: for every applicant in every year, it's higher than 20%. That means that by taking the 20% off the discount level instead of taking 20% off the pre-discount cost, the FCC has accelerated the movement of funding from voice to broadband.
Too bad it whipsaws applicants.
- Applicant don't have to keep track of two discount levels, one of which changes every year.
- It doesn't require a temporary re-write of the Form 471 to allow for different discount levels. Applicants could just add 20% of the pre-discount cost to the ineligible cost in Item 23b on the Form 471. OK, technically you'd also have to take the 20% off the BEAR and SPI, too, but why not just let people take a discount off the full amount and hit the cap 20% sooner?
- The effect on funding would be smoother. Here's how.
- Funding lost: To applicants using the BEAR, the change will appear as a loss of funding. How much smaller is the reimbursement check this year?
- Cost increase: To applicants getting discounts, the change will appear as an increase in cost. How much bigger is my phone bill this month?
Here's a table showing the effect for all applicants over the next 3 years. (Sorry, the 4th and 5th years won't fit.)
| Cost Allocation | Year 1 | Year 2 | Year 3 | |||||
| Original Discount | Funding Lost | Cost Increase | Funding Lost | Cost Increase | Funding Lost | Cost Increase | Funding Lost | Cost Increase |
| 90% | -20% | 20% | -22% | 200% | -29% | 67% | -40% | 40% |
| 80% | -20% | 20% | -25% | 100% | -33% | 50% | -50% | 33% |
| 70% | -20% | 20% | -29% | 67% | -40% | 40% | -67% | 29% |
| 60% | -20% | 20% | -33% | 50% | -50% | 33% | -100% | 25% |
| 50% | -20% | 20% | -40% | 40% | -67% | 29% | -100% | 11% |
| 40% | -20% | 20% | -50% | 33% | -100% | 25% | ||
| 25% | -20% | 20% | -80% | 27% | -100% | 5% | ||
| 20% | -20% | 20% | -100% | 25% | ||||
The "cost allocations" columns show the apparent funding effect if the 20% is taken off the pre-discount cost. I didn't have to do columns for every year, because the effect is the same every year. I didn't really have to do rows, either, since every applicant sees the same effect every year. Looks fair, doesn't it?
The other columns show the varying effect that applicants will feel as their discount percentage is cut 20%. Year 1 shows the strongest effect. Does it seem fair that applicants at the lowest discount level lose 100% of their funding? Does it seem fair that applicants at the highest discount level see a 200% increase in costs?
Why would the FCC do it? Well, the FCC is trying to cut voice costs. What I call "Funding Lost" is, from the FCC perspective, "funding moved from voice to broadband." Look at that column: for every applicant in every year, it's higher than 20%. That means that by taking the 20% off the discount level instead of taking 20% off the pre-discount cost, the FCC has accelerated the movement of funding from voice to broadband.
Too bad it whipsaws applicants.
Thursday, July 24, 2014
Meet the new rule, worse than the old rule
Oh, now I get it. The 7th Report & Order is out, and I'm still working my way through it, and I think I finally understand what they mean when they say you have a 5-year budget for "Category 2" (née Priority 2) expenses. I thought you'd apply in 2015, get your $150/student, then spend it any time in the next 5 years. I was wrong.
If I'm reading the order right, if you apply for any C2 funding in FY 2015 or 2016, then you have a total of $150/student (or $2.30/sq.ft. for libraries) to spend over the next 5 years. Whenever you need some C2 equipment, you apply, and if you're approved, the cost of that equipment is deducted from your $150/student budget, and if there's money left, you can apply for C2 again next year. There's a good example at the end of paragraph 105. And you're exempt from the 2-in-5 Rule, at least for the next 5 years. Let's call the new rule "the $150-in-5 Rule" (sorry, libraries).
Rationing C2 money is just bad thinking. If your incentive is encouraging applicants to spend too much, cut your incentive. But you know what? $150-in-5 could be better than 2-in-5. Except for the bookkeeping nightmare. And applying the cap to individual schools makes the bookkeeping much worse. Instead of keeping track of whether a particular location has gotten funding in the last 5 years, you have to keep of how much money that location has gotten. And I guess consortia have to keep track of every location of every member. That's not simplifying the process.
But it gets worse. Much worse.
First of all, what about the district's WLAN controller? You're not going to put a controller in each building; you'll get one or two for the whole district. Let's say you decide to buy a new WLAN controller and a new Internet router for the district. So you plunk down $48,000 for the WLAN controller and $12,000 for the router to cover your 10 schools, the district office and a maintenance garage. Well, it looks like you're supposed to divide the cost of the locations, so you allocate $5,000/location; the schools' cost is eligible for E-Rate funding. If you're a 90% district, you'll get 85% of that $5,000, or $4,250/school, for a total of $42,500. And then for each school you'll have to keep track of that number to see how much you have left on your $150/student allotment. And if one of your schools has fewer than 29 students, or has used some of its cap elsewhere, then you wouldn't get the full discount for that school.
But wait a minute, the maintenance garage has one computer connected to the Internet, but doesn't have a wireless access point, so now we allocate the $48,000 across 11 locations since the WLAN controller doesn't serve the garage, but the $12,000 router covers 12 locations, so now the pre-discount amount allotted to each school is $48,000/11+$12,000/12=$5,363.64. And then after 2 years, the maintenance crews get tablets [yes, they will] and they need Wi-Fi in the garage, so you install an access point. Oh, crap, now you have to give money back because the schools got funding based on a 1/11 share, and now they're only using a 1/12 share. If you're head's not ready to explode yet, think about the math when your statewide network upgrades equipment at the core. Suddenly the budget calculations of every district in the state are affected by whether I connect my maintenance garage to the Internet.
Second, what about changing enrollments? OK, paragraph 115 covers that. The good news: if enrollment at a school drops, you don't have to give the money back. [Got a school closing in the next couple of years? Think of it as a Wi-Fi equipment factory.] More good news: students that split time between districts (think vo-tech) can be double-counted. The bad news is for new charter schools. A new charter high school will frequently start up with just the 9th-grade class, then the next year accept a new 9th-grade class, and so on. It takes 4 years to reach full enrollment. Under this plan, they'd have to install their Wi-Fi infrastructure in 4 stages. That's costly and disruptive. And they have to make a guess about the availability of C2 funding in 4 years when they're planning the network. What if I have a school with 500 kids and I get my $75,000 in FY 2015, and then my enrollment climbs to 600 by FY 2017. Am I eligible for another $15,000? Not screwy enough for you? How about this: a district is opening a new school in FY 2017. The district is allowed to estimate how many kids will be transferred into the new school, but those kids were already counted in in calculating the cap for the existing schools they were crowded into in FY 2015. If it's a replacement school, the district will get $150 for each student for both the new school and the old school, and then just tear the equipment out of the closing school and distribute it around the district as needed.
Third, not every school's needs are the same.
If I'm reading the order right, if you apply for any C2 funding in FY 2015 or 2016, then you have a total of $150/student (or $2.30/sq.ft. for libraries) to spend over the next 5 years. Whenever you need some C2 equipment, you apply, and if you're approved, the cost of that equipment is deducted from your $150/student budget, and if there's money left, you can apply for C2 again next year. There's a good example at the end of paragraph 105. And you're exempt from the 2-in-5 Rule, at least for the next 5 years. Let's call the new rule "the $150-in-5 Rule" (sorry, libraries).
Rationing C2 money is just bad thinking. If your incentive is encouraging applicants to spend too much, cut your incentive. But you know what? $150-in-5 could be better than 2-in-5. Except for the bookkeeping nightmare. And applying the cap to individual schools makes the bookkeeping much worse. Instead of keeping track of whether a particular location has gotten funding in the last 5 years, you have to keep of how much money that location has gotten. And I guess consortia have to keep track of every location of every member. That's not simplifying the process.
But it gets worse. Much worse.
First of all, what about the district's WLAN controller? You're not going to put a controller in each building; you'll get one or two for the whole district. Let's say you decide to buy a new WLAN controller and a new Internet router for the district. So you plunk down $48,000 for the WLAN controller and $12,000 for the router to cover your 10 schools, the district office and a maintenance garage. Well, it looks like you're supposed to divide the cost of the locations, so you allocate $5,000/location; the schools' cost is eligible for E-Rate funding. If you're a 90% district, you'll get 85% of that $5,000, or $4,250/school, for a total of $42,500. And then for each school you'll have to keep track of that number to see how much you have left on your $150/student allotment. And if one of your schools has fewer than 29 students, or has used some of its cap elsewhere, then you wouldn't get the full discount for that school.
But wait a minute, the maintenance garage has one computer connected to the Internet, but doesn't have a wireless access point, so now we allocate the $48,000 across 11 locations since the WLAN controller doesn't serve the garage, but the $12,000 router covers 12 locations, so now the pre-discount amount allotted to each school is $48,000/11+$12,000/12=$5,363.64. And then after 2 years, the maintenance crews get tablets [yes, they will] and they need Wi-Fi in the garage, so you install an access point. Oh, crap, now you have to give money back because the schools got funding based on a 1/11 share, and now they're only using a 1/12 share. If you're head's not ready to explode yet, think about the math when your statewide network upgrades equipment at the core. Suddenly the budget calculations of every district in the state are affected by whether I connect my maintenance garage to the Internet.
Second, what about changing enrollments? OK, paragraph 115 covers that. The good news: if enrollment at a school drops, you don't have to give the money back. [Got a school closing in the next couple of years? Think of it as a Wi-Fi equipment factory.] More good news: students that split time between districts (think vo-tech) can be double-counted. The bad news is for new charter schools. A new charter high school will frequently start up with just the 9th-grade class, then the next year accept a new 9th-grade class, and so on. It takes 4 years to reach full enrollment. Under this plan, they'd have to install their Wi-Fi infrastructure in 4 stages. That's costly and disruptive. And they have to make a guess about the availability of C2 funding in 4 years when they're planning the network. What if I have a school with 500 kids and I get my $75,000 in FY 2015, and then my enrollment climbs to 600 by FY 2017. Am I eligible for another $15,000? Not screwy enough for you? How about this: a district is opening a new school in FY 2017. The district is allowed to estimate how many kids will be transferred into the new school, but those kids were already counted in in calculating the cap for the existing schools they were crowded into in FY 2015. If it's a replacement school, the district will get $150 for each student for both the new school and the old school, and then just tear the equipment out of the closing school and distribute it around the district as needed.
Third, not every school's needs are the same.
- How much Wi-Fi does a pre-school with 200 kids need? Just pay your cable company $200/month and they'll throw in a wireless access point; whatever district resources they need, they can get over the Web. Maybe you need to put a second WAP at the far end of the building; splurge and buy 802.11n, though 802.11g would be more than enough. Total cost? $125 for the WAP, $200 for the cable run.
- How much Wi-Fi does a 200-student technology charter high school need? Each kid will have a school-supplied device and a BYOD, so you'd better have at least 10 WAPs, and you're going to need some other drops in each classroom, so you're looking at a 48-port switch (and since you'll want 802.11ac WAPs, you'll need 10 Gbps ports on that switch), and those kids change classrooms every 40 minutes, so you'll need a WLAN controller. And you'll need access to the district WAN, so you'll have to install a router. With cabling and installation, we're over $40,000. And we haven't yet installed a lab for these kids to work on technology yet.
- How much will E-Rate support in those locations? $30,000 over 5 years.
- "greater predictability"
- "this approach maintains the E-rate program’s priority for the highest poverty schools and libraries... At the same time, this approach guarantees a broader distribution of funding for internal connections..."
- " promotes cost-effective purchasing"
- What predictability? I am pretty confident that all 90% applicants (or should I call them 85% applicants or 90%/85% applicants, or 90%/85%/70%-50%-30%-10%-0% applicants to include their voice discount) who choose to apply in the next 2 years will receive C2 funding. I'm not so confident for 80% (80%/80%/60%-40%-20%-0%?) applicants. 40% (40%/40%/...forget it) applicants? Don't waste your time. And even for 90% applicants, there is confidence of funding for the next 2 years, but after that, it's dicey. C2 is still a lower priority than C1, and once we've spent this one-time $2 billion leverage, where will the funding come from? Savings? Spare me.
- I don't feel like I need to rebut this; the two sentences I quoted rebut each other.
- My favorite part of the order so far. The text says that setting a budget for C2 funding will keep applicants from choosing more expensive C1 options, and then the footnote has comments which all say that limiting C2 funding causes applicants to choose more expensive C1 options. Setting a 5-year budget of $150/student, but then not providing enough funding to support that, is worse than the 2-in-5 Rule: applicants will overbuy right now, then try to shove as much functionality as possible into C1 in the future.
- Guarantee at least $5.5 billion for C2 over the next 5 years.
- Make the $150/student-$2.30/sq.ft. budget apply to organizations (billed entities), not locations. Take total enrollment per district and total square feet per library system. It drastically simplifies things, and removes the stupid idea that a pre-school needs as much Wi-Fi coverage as a high school. And stops student-transfer shenanigans. Also, with the per-district discount, there is now no reason for the complicated equipment transfer rules.
Wednesday, July 23, 2014
My growing bag of tricks
Hey, another Stupid USAC Web Tool Trick. [Wait, that name makes it look like I think USAC is stupid. I would never say that publicly. I meant that the trick is stupid. The tool is also stupid.]
Do you hate the Entity Search tool as much as I do? Why can't I put in more than one Search Criteria? Why can't I use a wildcard in the ZIP Code or Entity Number search boxes? Why can't I choose what columns display on that first table that appears? (At least the state appears, which is more than I can say for the Search Posted Form 470 tool results.)
So I was wondering this morning what characters would make the tool flake out, and I discovered a very cool, if not terribly useful, feature. Check out what you can do with that % wildcard in the Entity Name field. The instructions on the screen say "please enter at least 3 characters before the % sign." But the real rule is: "Your query string must be at least 4 characters long, including any wildcard(s)." Did you notice the (s)? That's right, you can use more that one wildcard. So, for instance, if you put in "f%dis%" (it's not case-sensitive), it will give you every entity that starts with "F" and has "DIS" somewhere later in its name.
Cool, no?
Of course, I took it to the extreme. Yes, %%%% is a valid query string, and will return everything. Well, it would return everything if it didn't make USAC's servers choke on the whopping list. But by using %%%% and selecting entity types, I can tell you that there are 21,965 libraries in the database, and 17,572 districts. And that there are enough schools to choke USAC's buffer.
Alas, this trick does not work on the SPIN Search tool, where it would really be useful in searching for DBAs.
Do you hate the Entity Search tool as much as I do? Why can't I put in more than one Search Criteria? Why can't I use a wildcard in the ZIP Code or Entity Number search boxes? Why can't I choose what columns display on that first table that appears? (At least the state appears, which is more than I can say for the Search Posted Form 470 tool results.)
So I was wondering this morning what characters would make the tool flake out, and I discovered a very cool, if not terribly useful, feature. Check out what you can do with that % wildcard in the Entity Name field. The instructions on the screen say "please enter at least 3 characters before the % sign." But the real rule is: "Your query string must be at least 4 characters long, including any wildcard(s)." Did you notice the (s)? That's right, you can use more that one wildcard. So, for instance, if you put in "f%dis%" (it's not case-sensitive), it will give you every entity that starts with "F" and has "DIS" somewhere later in its name.
Cool, no?
Of course, I took it to the extreme. Yes, %%%% is a valid query string, and will return everything. Well, it would return everything if it didn't make USAC's servers choke on the whopping list. But by using %%%% and selecting entity types, I can tell you that there are 21,965 libraries in the database, and 17,572 districts. And that there are enough schools to choke USAC's buffer.
Alas, this trick does not work on the SPIN Search tool, where it would really be useful in searching for DBAs.
Tuesday, July 22, 2014
Vaporware
Where is that 7R&/EMO? The E-Rate 2.0 release date is slipping. That's what they get for trying to add and remove features after beta (the RFC in March). Some of those feature changes are going to cause problems:
- The five-year C2 budget was a fine idea, but it's going to hamstring competition if changes aren't made.
- Wimping out on the reduction to the top discount level creates a good deal of complexity without saving much money, or changing the perverse incentives.
- Phasing out phone service by cutting the discount level was not the simplest or fairest way to go about it (it triples costs for 90% applicants, and reduces funding for 20% applicants to zero).
- Sunsetting the per-student funding cap after 2 years really complicates the calculation for applicants: do I take the $150/student bird in the hand, or wait 2 years for the uncapped funding bird in the bush?
Friday, July 18, 2014
Where have all the dollars gone?
I saw a Funds for Learning analysis applying the purported changes in the new reform proposals to past years to see what effect it would have had. Of course, I jumped right to the graphs. But in the first graph, I was distracted by the numbers, because they didn't add up. FFL has total P1 demand for 2013 at $2.551 billion. But USAC's 2013 Demand Estimate said the total P1 demand was $2.709 billion. Why are those numbers different?
Then I decided to check FFL's numbers for broadband vs. non-broadband. So I went to the table of funding by category that USAC sent to the FCC in June. I dumped it into a spreadsheet to play with. The total of the requests on that table is $2.103 billion. Somehow that table says requests were 22% less than the Demand Estimate.
Let's see what the Data Retrieval Tool (DRT) says. The total ($2.719 billion) is just a little higher than in the Demand Estimate.
Say, it looks like about $452 million in P1 funding was denied, and $139 billion in P1 funding is still in review, for a total of $591 million. That would explain the difference between the Demand Estimate and the recent data estimate. But the that isn't what USAC said the table was.
Hmmm....
Generally, it's easy to say what's "broadband." OC-1 (50 Mbps), yes. E-mail service, no. But some things are a bit nebulous. ATM and Frame Relay, for instance, are variable-speed. And what about T-1s? I think 1.5 Mbps falls short of most standards for "broadband," but you could bond them.... Is the FCC really going to toss T-1 lines out of the program? If not, will they toss out PRIs? They're basically specialized T-1s.
Leaving all the questionables in the "broadband" category, I find that demand will drop about 32%. Taking out all the questionables, demand will drop by 40%. (FFL, by the way, estimated 35%.)
If we use that 40% number, 2013's $2.7 billion in demand would have been only $1.6 billion. And if USAC reductions and denials were 8.5% of the total (which is where they are now), approved funding would be $1.5 billion. So if we get a little inflation over the next few years, we could make it to the $1 billion/year that we'll need to fund broadband to provide C2 funding once every 5 years (assuming $150/student and negligible funding for libraries and the continuing non-participation of most private schools).
But spending on broadband is not going to stay flat, especially if you take away funding for T-1 lines.
The numbers only work if we're unrealistically optimistic and ignore monkey wrenches like voice not being fully phased out for years.
Then I decided to check FFL's numbers for broadband vs. non-broadband. So I went to the table of funding by category that USAC sent to the FCC in June. I dumped it into a spreadsheet to play with. The total of the requests on that table is $2.103 billion. Somehow that table says requests were 22% less than the Demand Estimate.
Let's see what the Data Retrieval Tool (DRT) says. The total ($2.719 billion) is just a little higher than in the Demand Estimate.
Say, it looks like about $452 million in P1 funding was denied, and $139 billion in P1 funding is still in review, for a total of $591 million. That would explain the difference between the Demand Estimate and the recent data estimate. But the that isn't what USAC said the table was.
Hmmm....
Generally, it's easy to say what's "broadband." OC-1 (50 Mbps), yes. E-mail service, no. But some things are a bit nebulous. ATM and Frame Relay, for instance, are variable-speed. And what about T-1s? I think 1.5 Mbps falls short of most standards for "broadband," but you could bond them.... Is the FCC really going to toss T-1 lines out of the program? If not, will they toss out PRIs? They're basically specialized T-1s.
Leaving all the questionables in the "broadband" category, I find that demand will drop about 32%. Taking out all the questionables, demand will drop by 40%. (FFL, by the way, estimated 35%.)
If we use that 40% number, 2013's $2.7 billion in demand would have been only $1.6 billion. And if USAC reductions and denials were 8.5% of the total (which is where they are now), approved funding would be $1.5 billion. So if we get a little inflation over the next few years, we could make it to the $1 billion/year that we'll need to fund broadband to provide C2 funding once every 5 years (assuming $150/student and negligible funding for libraries and the continuing non-participation of most private schools).
But spending on broadband is not going to stay flat, especially if you take away funding for T-1 lines.
The numbers only work if we're unrealistically optimistic and ignore monkey wrenches like voice not being fully phased out for years.
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