Re: [ga] Transfers and the Policy-Development Process

[DannyYounger@cs.com]

Thomas, 

It is clear that the implementation process cannot proceed in an 
unaccountable vaccuum. You are correct in asserting that "Code is Law", that 
we should properly fear code that might be manipulated, and that we cannot 
blindly trust those that formulate such implementations without proper checks 
and balances...  even so, I do note that the FCC does manage to handle 
implementation concerns in a fairly straight-forward manner with processes 
that call for a Notice of Proposed Rulemaking, a public comment period on the 
implementational details, etc. -- it can be done (even without the formal 
rigidity of the Administrative Procedures Act).

And yes, there are proposals even for reform of the FCC itself... one such 
proposal which called for even greater transparency is noted at 
http://www.tiaonline.org/policy/fcc_reform.cfm

My point is that the DNSO is chartered primarily to develop and recommend 
substantive policies.  That is its role.  The role of implementing policy 
advice belongs to another group, the Executive branch -- the President and 
his Staff.  But perhaps you are saying that we spend so much time on 
implementation concerns because we just don't trust the staff to act in our 
best interests... you may be right.  I guess our goal should be to establish 
ways to regulate the implementation process as well as to better define the 
policy-recommending process.

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