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WASHINGTON -- July 21, 2009: In a letter to new FCC Chairman Julius Genachowski, FCC Commissioner Robert McDowell offers some suggestions on "achieving the important public interest objectives" of reforming the FCC.

As he did in an earlier letter to Commissioner Michael Copps when Copps was serving as acting chairman, McDowell recommends a "thorough operational, financial, and ethics audit of the commission" and related entities such as the Universal Service Administration, the National Exchange Carrier Association, and the federal advisory committees. He says he envisions the audit "as an examination akin to a due diligence review of a company as part of a proposed merger or acquisition, or after a change in top management."

McDowell believes the audit "would be a meaningful first step on the road to improving the agency," and would like to take public comments and comments from commission staff, and also allow commission staff to comment anonymously. In the financial review, he would like to see the contracting process looked at, as well as processes related to collecting and distributing fees, as well as a look at regulatory fees.

McDowell also recommends that the FCC's strategic plan be updated and republished; he says, "Completing this task would create a solid framework for future actions and demonstrate our commitment to transparency and orderliness, each of which is critical to effective decisionmaking."

McDowell also says a potential restructuring of the FCC should be considered, saying that, although he isn't suggesting "change for the sake of change," there are ways the commission could increase its efficiency. He also wants to see improvements to both external and internal communications, with at least six months' notice on open meeting dates and better coordination among FCC offices.

Genachowski Responds

Genachowski responded with a letter agreeing that FCC reform "is a matter of great urgency." He notes that he has appointed Mary Beth Richards as special counsel for FCC reform "to ensure high-level attention to this vitally important issue," and that the FCC's general counsel and managing director will be working with Richards on a review of FCC processes and suggestions for improvement and reform. The FCC is also opening an internal website where employees can make suggestions for reform; that site will later be opened to the public.

Genachowski writes, "The ongoing review process ... will provide a framework for institutionalizing the values of openness, participation, fairness, efficiency, and accountability that I know you, Commissioner Copps, and I all share."