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Top Ten Things You Should Know About Filing Comments on the FCC's Data Review

by: Greg Elin, Chief Data Officer

August 9, 2010 - 05:36 PM

[[wysiwyg_imageupload:43:height=100,width=71]]Post: FCC Data Innovation Initiative Journal, Day 41, Washington DC. For Comment: Media Bureau MB Docket No. 10-103; Wireline Competition WC Docket No. 10-132; Wireless Telecommunication Bureau WT Docket No 10-131.

Resources: reboot.fcc.gov/data/review

If you've given any thought about data at the FCC and filing comments on the opening round of the FCC's Data Innovation Initiative – the Public Notices of Data Reviews released by the Media, Wireline Competition and Wireless Telecommunications Bureaus - this blog post is for you. Initial comments are due this Friday, August 13.

Though the scope of the Public Notices is significant and welcomes comments on any or all of 340 data sets across three bureaus, filing comments does not have to be a major project. You can make a difference with as little as 15 minutes of effort. The following Top Ten Things You Should Know explains why.

  1. You don't have to make your filing a multi-day effort. The conversation is just starting. If you only have 15 minutes, use that time to layout the big concerns. This stage doesn't have to be a research project. Simply share with us what you already know needs attention and rethinking. Think of your comments as writing a quick email to a colleague about your long standing concerns about FCC data. And if you are working on more substantive analysis and comments of how to improve FCC data, please keep at it. This filing is perfect timing.
  2. Don't feel you need to comment on every data collection. Comment on the ones you know and are important to you. Treat the data collection list as a helpful guide and don't think you need to comment on all collections. Ignore the list if you want. (Identifying data sets by OMB Paperwork Reduction Act approvals is just one lens onto Commission data; use it to the extent it is helpful.) We offer the spreadsheets of the data collections in each Bureau for transparency sake and as a handy reference. We expect people to file comments about the data and data filings with which they are already familiar. But we also want to make it easier for others reading such comments to learn about the data set being discussed and to provide thoughtful replies. The data collection list exists as a guide and reference, not a threshold or checklist for participation.
  3. Share high level thoughts on FCC current data and future data practices. The Public Notices are clear that we are seeking comments on all aspects of how we collect, manage, analyze, and share data. High level comments about the forest may be even more important at this stage than specific comments about individual trees. What data collection techniques are standard now that might have been cutting edge even a few years ago? What issues, or solutions, cut across multiple data sets?
  4. Repeat yourself. File anew data-related comments you filed before. It's OK, even encouraged, to re-file comments or link to comments on data issues you've previously filed. Why? Because we are doing a "zero-based review" of all agency data, we are putting everything on the table for review, even data sets that have been reviewed recently, as if we were starting from scratch. The Paperwork Reduction Act requires agencies to review and seek re-approval of a data set at least every three years to keep data current to changes in technology and the market. In addition to those periodic reviews, we are trying a larger, agency wide review to pursue macro-level changes across multiple data collections. Another reason to be comfortable re-filing data-related comments are the new resources the FCC has committed to tuning our data for the digital 21st century including Chief Data Officers in the three Bureaus posting the Public Notices, a Chief Data Officer for the agency and our first-ever Geographic Information Officer.
  5. File more than one comment. Don't let the perfect be the enemy of the good (or even the just in case). Start your bullet list of points right now as you are reading this blog post and file some quick comments and make yourself a participant in this conversation. Feel free to file comments today and later this week as you think about them.
  6. File comments that help us prioritize. We are reviewing, for purposes of improving, all data collected and used by the Media Bureau, the Wireless Telecommunications Bureau, and the Wireline Competition Bureau. Particularly useful are comments helping prioritize what data and data practices to revise first.
  7. Apart from the underlying data sets, the Public Notices are identical in the three Bureaus. File on the Notice that seems most relevant. Our Electronic Comment Filing System also supports filing one comment across multiple proceedings.
  8. Share links to existing articles, papers, blog posts. A good filing would be one that lists existing articles, research papers, and blog posts discussing ways the FCC could collect, use, and disseminate data. Coordinate a list with a few colleagues. Keep the list manageable for us, between 10 and 20 links. You can also attach whole documents with your filing. Provide a paragraph or two of context for the list describing what themes in the linked material are most applicable.
  9. We already know where we are, so let's talk about where we need to go and how to get there. Pointing out the obviously wrong is always welcomed. Just please recognize there are real reasons the FCC might not be collecting data that to you seems a no brainer and possible statutory reasons we are collecting data that may no longer seem relevant. Like any organization, at any given moment the FCC is juggling new ideas, legacy systems, and resources. Accept there are real challenges associated with modifying data practices and help us overcome those challenges. Don't simply tell us we are doing X when we should be doing Y. Instead, share with us workable road maps to get from X to Y. We know our forms could be easier; share examples of easier to use forms and screens. We know duplication exists in our data; tell us which duplications are easiest and best to address first. We know we want more transparency in our data; offer recommendations about which data sets are most valuable to publish first what formats and techniques make the data most useful. If we should be using RDF and taxonomies, what three steps do you recommend to get started? Do we do one sector at a time, or focus on just a few attributes across the breadth of FCC data? If we should be collecting data in XML, what standards or other trends should we be aligning with? If we need to share collected data better, who are the experts and what are the techniques that can help us enable data sharing while addressing legitimate privacy and proprietary concerns? If a data collection requires significant effort to gather, what is a better way to gather the information?
  10. Finally, tell us what things we doing well with data at the FCC that we can build further upon. More than 40 specific databases searches are available on FCC.gov. We offer dozens of data sets for bulk download. Improvements recently made our Electronic Comment Filing System easier to search and use. We know there's more work to do. That's why we are doing a zero-based data review. But building upon what we are already doing well speeds change. What existing assets can we extend to provide a strong foundation for further improvements?

There you have it. Ten Things You Should Know that should making filing comments on the Data Review Public Notices by the end of this week a snap. So stop fretting at the seeming enormity of improving data at the FCC or worrying you do not have time to file comments on the Public Notices this week. Detailed recommendations on our data collections, high level points, and even quick listings of things to change are all encouraged. In the time it takes to watch a couple Seinfeld reruns you could help improve data at the FCC.

Never filed before? You can file using the ECFS Standard form. Just enter the appropriate proceeding number (10-103, 10-131, or 10-132) and complete the form. To see already filed comments, follow these links: MB Docket No. 10-103 comments; WC Docket No. 10-132 comments; WT Docket No 10-131 comments.

Updated: April 16, 2012 - 10:32 AM
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