SpectrumTalk

FCC
Web
Site:

The Nation's

Communications Policy "Attic"

The Smithsonian Institution is sometimes called the "nation's attic" for its jumbled collection of historical artifacts. The jumbled nature of the FCC's web site deserves a similar name. All sorts of information is there, it's just hard/nearly impossible to find. Last month the IP Democracy blog labeled FCC "The Worst Communicator in Washington". While much of the post deals with the specifics of the 700 MHz auction proceeding, here are the comments about the web site:

"The FCC’s poor communications skills are evident all the way down to the agency’s website, that most public and constant of communications tools. Have you ever tried to search filings or decisions at www.fcc.gov? I’ve been conducting research at the Commission’s web site for years and years and my heart sinks every time I have to do so.

Let me put it this way: without a “Docket Number,” the average user can’t find anything on the FCC’s website. Even with a Docket Number, users have to choose from among eight different types of databases and if, by chance, the right database is selected, the results can be a garbled, gargantuan mess. Getting a hold of the Docket Number is not the easiest thing in the world for the uninitiated, either.

On top of the searchability problems (and they are vast, vast, just trust me), nothing at the FCC’s website is in HTML, beyond the basic informational, static shell. Everything is published in Word (!) or Acrobat, and sometimes .txt, so even if a user finds the relevant document, it has to be downloaded or viewed in just plain text format. A real nightmare."

Readers may recall previous posts of mine on the topic. They haven't had much impact, so maybe it is time to be more specific:

1) Search engine. In a large website, an efficient search engine is vital. As mentioned previously, FCC search engine is dated - apparently dating from the early Hundt chairmanship. Many other agencies just use Google's free customized engine.

2) Clutter, clutter everywhere. Apparently there is no self control at all on putting more information or more links on the FCC home page. The graph below shows the number of words and links on the home pages of various agencies:

(Raw data available here.) FCC has more links on its home page than any other agency and just loses to Interior, that Internet powerhouse, on number of words! Truly record setting clutter!

a) Too many links for the same document. Does any other agency routinely give links for both MS Word and Acrobat copes of every document? (Not to mentioned .txt versions of older documents. There were good historic reasons for why this started but they no longer apply.

[Note that since this was originally written, an FCC source told me that the reason for the retention of both .txt and .doc versions of documents is requests from the visually disabled community who have trouble with .pdf documents and special software they use. Whether this is still true is uncertain as I note that no other agency, even the HHS group that works with the disabled, has this multiformat clutter. I suspect that the problem is more the lack of HTML versions of official documents that most other agencies have. I note also that in the docket files in ECFS many of the documents are in scanned versions of .pdf that are also unreadable to the disabled. FCC has never done anything to urge commenters to avoid scanning documents into .pdf by using electronic conversion.]

Above is data from EDOCS (in this case Docket 04-186) that gives 15 different links for the same NPRM! Card-carrying FCBA members and their paralegals may understand why and which one they want, but I doubt if anyone else does. I can not find similar clutter at any other agency.

b) No other federal commission clutters its home page with individual commissioners's links. Not to mention a separate link to their photos. Don't believe me? See if you scan find comparable links to commissioners on the home pages of: ABMC, CPSC, DNFSB, EEOC, FRB*, NLRB**, NRC, NTSB, SEC

* Note FRB description of recent improvements to their home page. FCC home page design is little changed, except in increased clutter, since the early Hundt chairmanship.

** NLRB was recently honored as having one of the 5 best web sites in the federal government. The citation said “Excellent navigation scheme. Site is well organized and

very easy to follow. Good guidance. Electronic reading room with a lot of available information.” FCC was not one of the other 4 honorees.

Award winning NLRB web site

3) Is anyone in charge here? I suspect that the root cause of this problem is that management of the web site has been delegated to such a low level that the webmaster can not say no to anyone's request to add more clutter to home page. Somebody has to be in charge for both the content and overall design that reflects well on the agency and its mission.

4) Difficulty of finding information without prior details. As the IP Democracy quote above says,

"Let me put it this way: without a “Docket Number,” the average user can’t find anything on the FCC’s website. Even with a Docket Number, users have to choose from among eight different types of databases and if, by chance, the right database is selected, the results can be a garbled, gargantuan mess. Getting a hold of the Docket Number is not the easiest thing in the world for the uninitiated, either."

Card carrying FCBA members, or their paralegals, don't have a problem here. But anyone else does. It is clearly the least user friendly part of the web site. For the elite involved in huge mergers there is a more user friendly interface: The OGC Transaction Team runs a nice corner of the website dedicated to "transactions" - generally meaning large corporate mergers. It is one of the bright spots of the FCC website, but why does this type of convenience only apply to mergers? The Transaction team site is indexed by the pending (and past) major mergers by name - not multidigit docket number - and gives access to both filings and FCC actions. By contrast, those of us who deal with rulemakings must navigate both EDOCS and ECFS to get documents and in most cases have no index.

OET has another user friendly way to find dockets in its jurisdiction. Both the OGC and OET indexes and great contributions to the FCC website that address the concerns that IP Democracy mentions, but why this piecemeal approach for only 2 small parts of the Commission? Why not a general solution?

5) Lack of links to specific FCC rules or statutes. In the few cases where the website cites a specific law or FCC rule, there is either no link to it or just a link to the general GPO CFR website. Perhaps no one has realized that GPO allows links to specific laws, e.g. 47 USC 151 or rules, e.g. 47 CFR 2.701. GPO even has a page telling you how to generate such links.

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A problem recognized is a problem on its way to a solution

FCC seems to be in a bad state of denial with respect to its home page and web site. some of these problems can be fixed simply, other will need a more expensive site redesign. But recognizing the problem and interacting with the public on alternatives would be a good place to start.