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Sunday, March 09, 2014

Another serving of Pai

I like Commissioner Pai's style.  His statements always seem to be more straightforward than most of the commissioners I've seen over the years.  And he's willing to stake out his own position.  His response to the recent request for comment is a good example of both.  He comes right out and says that the notice asks the wrong questions, and asks them the wrong way.

As usual, however, I disagree with him on policy.  Towit:
  1. "Reform should mean eliminating the priority system...."  No, I think we should triple down on priorities.  My comments on this summer's NPRM included 6 priority levels. I think priority levels are the correct way to ensure the program accomplishes the Commission's priorities.
  2. "Reform should mean abolishing the discount matrix...."  I don't think all districts deserve a 75% discount, as Commissioner Pai has suggested.  I think a top discount level of 65% will be more effective in reducing waste, fraud and abuse, and provide a stronger incentive to make cost-effective choices.  Also, I like the idea of giving a larger discount to districts with more needy children.  I'm for simplifying the matrix, but not abolishing it.
I also disagree with him on procedural matters, though I don't agree with the Commission's approach, either.  Basically, he's saying that the recent request for comment should have been a Notice of Proposed Rulemaking with concrete proposals.  I take the other approach.  This summer's NPRM should have been a request for comment.  I'm no lawyer, but it seems to me that a Notice of Proposed Rulemaking should be full of proposed rules, not reform concepts.  Instead of saying, "What do you think about changing the discount level?" an NPRM should say, "We plan to make the following changes to the discount matrix...."  This summer's NPRM didn't do that, so it should have been a request for comment.  Once the FCC boils down all the comments in Docket 13-184, they should do an NPRM to let us know what rules they plan on making.
Still, I just can't get my fill of Pai.

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