A light at the end of the black hole?

The FCC is requesting comments on the recommendations from its internal Report on FCC Process Reform. OK, I'll comment.

There is only one E-Rate-specific recommendation: 5.39: Parties Aggrieved by a USAC Decision Must Seek Review From USAC Before Seeking Review From the FCC.  I can see why the FCC is doing this: "Requiring parties to first file appeals of USAC decisions with USAC would reduce the number of appeals coming to the Commission...."  Yes, but not by as much as they're hoping.  Very few appeals are filed as the result of USAC being boneheaded and not doing what it knows it should.  Most appeals are the result of USAC making its best guess on what to do, and the applicant disagreeing that the correct guess was made.  So most appeals are going to end up at the FCC, anyway.  Still, I don't think it does any harm to at least give the USAC appeal a try.  I often appeal to USAC even when I know it will fail, just to see if I can get any more information.

USAC does get one other mention, in recommendation 1.12. "For example, one avenue for increasing speed of disposal of USAC items would be to resolve low-dollar appeals and those that are consistent with precedent with fewer layers of review."  Yes!  Really, how much FCC staff time does an appeal for $388 warrant?  Elsewhere, the report suggests creating boilerplate language.  This should be the standard reply for amounts less than $500: "Fuggedaboutit.  The money's yours.  Signed, The FCC."  Done.

"Recommendation 1.1: Efficient Intake Analysis and Relevant Timelines" looks promising.  I would love to have a timeline for my appeals.  But reading further in, it's clear that the timelines would be kept secret from the public.  So we'd still just get the "We have your appeal.  No decision has been reached yet." response.  Later, they say "Act on Petitions for Reconsideration within 180 days, or deem the petition denied."  Oh, hell no.  It's the bizarro world version of my "a decision in 90 days or your appeal is automatically granted" policy proposal.  If a Petition for Reconsideration filed with the WCB is denied, you can bet it will generate a Petition for Reconsideration the full Commission.  (Don't know about the levels of appeal?  Here's a table.)  And at the full Commission level, it is just a slap in the face to some poor school employee who made a mistake and is hoping the FCC will be merciful and save his job by giving him a waiver, to have the Commission say, "Sorry, we couldn't get around to it.  We're denying your appeal without considering it."

I like "Recommendation 1.21: Increase Tracking Transparency of Pending Items," which includes the idea of "developing a detailed inventory of pending matters, and, over time, making that inventory public."  That's great.  No longer would we have to send appeal status requests, only to get the reply "We have your appeal.  No decision has been reached yet."  Instead, we could just go on the dashboard to see that appeal was received and no decision had been made.

Hey, I've got a suggestion for implementing Recommendation 2.28, which includes the idea that "The FCC staff should review existing data collections to determine if there are collections that should be discontinued."  How about taking a look at Item 26d on the Form 471?  It is a number that can't really be calculated, takes hours to estimate correctly, and is not used by anyone.  A completely useless waste of time.

My takeaway: many of the titles of the recommendations look great, but the substance is either worthless or harmful.  Except Recommendation 1.12, which might have a marginally positive effect.