Lasar Letter on the Federal Communications Commission    
 


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Five ways that fcc.gov could make itself more accessible

by Matthew Lasar  Dec 12 2007 - 6:14pm     

Sometimes I get interviewed on the radio about some subject related to the Federal Communications Commission. Invariably the host asks me the same question: "What can the public do about this matter?"

In response I rattle off the names of some good groups to contact: Free Press, the Benton Foundation, the Media Access Project, The Prometheus Project, etc, etc, etc.

After which the host invariably adds with a perky, helpful tone: "And you can also contact the FCC at dub dub dub dot fcc.gov. Right?"

"Er, uhum, rite . . ." I mumble, and hope that we move on to the next question quickly.

You see, I never tell civilians that they can contact the FCC on some matter, because they usually can't. Go to fcc.gov now and see for yourself.

Are you there? As you can tell, the home page of the site is a blizzard of links and options. After a minute or so you'll notice a link on the left: "Contacting the FCC."

But if you go to that page, you'll find no easy way to reach the Commission on a specific issue. Sure, there are e-mail links to the commissioners, but I can't seriously promise anyone that they will read, much less respond, to something Jane Q. Public e-mails them, because the chances are that they won't.

Up top on the right there's an "e-filing" link, but it connects to another blizzard of incomprehensible options.

By now, most people have given up. The very plucky visitor will wander around some more, go back to the home page, and notice a link further down on the left. There they will find the "Electronic Comment File System" page, which allows users to file very short comments on about twelve specific issues. The "last reviewed/updated" bug on the bottom right says it hasn't been changed since January 2005. Actually, it looks like it was updated about six months ago or so.

My guess is that by now about 80 percent of potential commenters have given up trying to get their viewpoint to the FCC. And that's just a shame. Some of them will go to various public interest or lobbying sites, click some form, and send off an auto comment that nobody at the FCC will read except the database geek.

The rest will just go on with their day, a little more frustrated and cynical.

It's wrong. It's bad. With a few changes, the FCC could dramatically upgrade the quality of correspondence they get from the general public. Here's how:

#1. Put a BIG link to the FCC's main comment form on the top right of its home page.

The best FCC comment form is here. It's the "expert form." It allows you to write a statement on your computer in Word, Word Perfect, or pdf format, then upload it to the FCC. That page should be a one-stop instant eyeball option for even the most uninitiated fcc.gov visitor.

#2. Explain to the public how to use the expert form.

The FCC has this 26 page comment manual, almost five years old, that most users will give up on in 12 seconds or less. The expert form page need only have the following to become more widely used:

  • An explanation of the docket system. Every big FCC issue has a docket number that you have to plug into field one of the expert form. The proposed XM/Sirius merger is 07-57. FCC Chair Kevin Martin's latest media ownership proposal is 06-121. The expert form should include a short introduction that explains this (like what I just wrote here, or something like my longer version here).
  • A regularly updated list of the top 30 docket issues, linked to the appropriate published Notice of Proposed Rulemaking on the matter. This list should appear on the same page as the comment form or be very visibly linked on another page. The agency does have a full list of its dockets here, but it's pretty hard to find.
  • An expanded comment field at the bottom. If people don't want to upload a document, the comment field at the bottom of the expert form should be at least half a page in size, and it should be able to wrap text (duh), unlike the present field.

While I'm on a roll, here are some other suggestions.

#3. Broadcast open commission meetings on the top of the FCC's home page.

Why can't the FCC do what does? Just put an object link at the top of the home page for people to click if they want to watch and hear the meeting. Of course, to do this the FCC would have to get a server that can accommodate more than the 200 people that the current one can handle, but given that the present population of the United States is over 300 million citizens, that would seem like an appropriate move.

#4. Add rss or xml aggregators to the site.

I may be wrong, but I think at this point the FCC is one of the few consumer oriented federal government agencies that doesn't include an xml/rss news feed. It wouldn't be hard to join the club. There are probably about 200 million bloggers around the planet who could show the Commission's staff how to do this, not a few of them recent graduates of Junior High School.

#5. Make the FCC's public comments searchable by subject or word phrase.

Ok. This suggestion is the biggie, I'll admit, and can't be implemented in a fortnight. Right now if you go to the FCC's carefully buried "Search for Filed Comments" form, you can only search via the docket number, the party for whom the comment was filed, or the attorney, and a few other criterion irrelevant to most of us.

What you can't search for is word phrase or subject. This is what makes the application so inaccessible to most people. They'd like to be able to type in "net neutrality" and see what's been filed recently, but the technology forbids this activity.

But hope springs eternal. Java library function programs like Lucene can read pdfs, index their contents into a database, and render them vastly more searchable. The UC San Franciso Legacy Tobacco Documents Library is one of the big success stories in this regard. Its programmers have turned the library's nine million or so pdfs into a fantastic searchable database.

Implementing all of these changes, of course, would require a commitment to making the Federal Communications Commission a meaningful resource for ordinary people, and not just a vestibule for corporate law firms and techo saavy interest groups with a specific agenda.

Surely that commitment is there at the FCC, somewhere. And if it is not there, we are more than justified in asking why.

Got a suggestion for the FCC's Web site? The agency's Web master can be reached at . Of course, LLFCC would like to get your feedback too.


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Cooperative Civic Media Over-Site
Anonymous  Dec 12 2007 - 11:24pm   

I have shared your critical view of the FCCs web-site, and the FCC for some time.

The solution I would like to see us implement, and I have only made rough sketches for myself and a few others, but which could incorporate much of what you have detailed is this: we develop the site ourselves as an organ of public governance.

We can incorporate complaints filings on all issues pertaining to media. We can catalog and cross reference based on geography and provide our information to legislators and public officials at each layer of government. You see, part of the fallacy is that media is handled/regulated at one layer of government. It isn't, and it shouldn't be. (We may express doubt that it is really 'regulated' at the Federal level.. regulatory capture is the phrase that fits best.)

Michael Maranda
http://wrythings.net


 
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