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ISP-Planet Fixed Wireless

Politics

How to Talk to the FCC

So, you've been in business long enough to know what rules you like and what rules you don't. It's time to talk to the government.

by Marlon Schafer
Consultant and CEO, Odessa Office
[April 27, 2004]
Email a colleague

You feel you have a good enough grasp on the real world issues that you'd like to talk to the government about ways to make the business climate better. There are a large number of ways to go about this process. I'm going to hit on one: a trip to the FCC's offices.

Because the folks at the FCC have been so helpful as I've learned how to do this, I'm not going to get too deep into the administrative side of the process. The staff at the FCC will guide you as needed. My goal with this article is to help you gain enough general knowledge to be comfortable in even asking for a meeting.

I've been to the FCC a few times now. It's been a very different experience than I would have thought it would be. And were it not for a chance encounter with Dr. Robert Pepper I probably never would have taken the time to set any meetings up.

You see, as far as I could tell, the FCC was a group of people bent on protecting the incumbents and eventually killing the little guy off. What I found out was that they make rules according to the laws that guide them and input that they get from those affected by the rules. As it turns out, the incumbents are, generally, much better about feeding information to the FCC than are the startups (WISPs in this example).

Now I can see that the people at the FCC are hungry for information. Like a computer, if garbage data goes in, garbage rules come out. And we are largely to blame for that. We (the WISPs) need to do a better job of making sure that good data is getting to the FCC. We do have some groups that are starting to make some inroads there: WCA, Part-15, and recently WISPA is getting started up again.

It's been made clear to me that the FCC likes to hear from trade groups as much as possible. That tends to filter out fringe ideas and saves the staff time and energy. It's also important that they be kept up to date on what is happening now outside the beltway and that means that you, the WISP need to find ways to build relationships with FCC personnel either via phone calls, e-mail exchanges or better yet, face to face visits.

The first time I put together a meeting was in June of 2002. We did a "WISP Training Session".

Before we went there for the first time, I spent a lot of time on the phone with a gentleman by the name of Robert Cannon. He did all of the coordination for the "event". My time with Robert was very important, more so than I think I understood at the time. You see, there are rules, politics, and culture that all have to be kept in the back of one's mind as you interface with the commission.

If you go there to ask for something (lobby) you have to file a document called an Ex Parte. It's basically a public disclosure document. In it you have to tell who you talked to and what you talked about. Not a big deal and something that the staff can help you with.

When you go in, make sure that everyone is on the same page. Do not start arguing in front of the FCC. It's one of the worst things that you can do. This is not to say that everyone has to be in total agreement. Differing points of view are not totally bad, but don't try to change the other side's mind during your time with the FCC.

Look professional. I'm from a very rural community and thus have been quite tempted to live the stereotype and show up in a straw hat and bib overalls. I've somehow managed to corral that temptation and always come in dressed nice casual (button up shirt, slacks and sport coat) or a suit. Don't come with a day's worth of beard, greasy hair, etc. The example that was used for me back when I learned how to "dress for success" was to look like a banker.

Meetings will usually be limited to about 1 hour (30 minutes for commissioners). So say what you have to say early on and add detail as time allows. If the meeting runs overtime, don't be offended if folks walk out on you. They likely just have other commitments booked up already.

Each commissioner is slightly different in regards to how they run their offices. Some will give you quick and easy info on how to get a meeting with them. Others make the process a bit more challenging.

The first thing you should do is write yourself some notes. Also have a note pad handy when you contact the FCC. Once you have your thoughts in order and written down (so you don't leave anything out if you find yourself getting a bit nervous) pick up the phone and dial 1-888-call-fcc. Once you get the operator ask for the phone numbers of the people you'd like to talk to. The list of commissioners is right on the FCC's home page. If you aren't sure who you should talk to, just ask. The people that answer the phone are very helpful in pointing a guy in the correct direction.

And there's always the FCC phone book.

I start out my conversations with the office managers by telling them who I am, what I'd like to talk about, and when I'd like to be able to meet. I've not had many questions come up from those short conversations. Usually what I do end up with is an e-mail address for the person that would be the one that coordinates the meeting.

I also try to get a list of topics to the FCC folks at least a week or two ahead of the meeting. This way they are able to come to the meeting somewhat prepared mentally and don't have to try to shift gears on the fly. As the meetings are usually so short, I try to cover the issues from 30,000 feet first and drill down as time and interest allow.

It was also pointed out, in no uncertain terms, that there needs to be "leave behinds". That's more info and detail than you'd have time to get into in the meeting. For example, when I take a team (4 to 6 people) to the FCC, we create a list of 6 to 10 talking points. Before we get there each member of the team will add greater detail as he sees fit to some or all of the talking point items. These can be done via electronic means or by paper handouts or both.

Armed with this knowledge, I'd encourage you to at least pick up the phone or drop an e-mail to the folks at the FCC on occasion. Let them know what's happening out in the trenches.

—End

Related articles:
  [April 27, 2004] How I Talked to the FCC
  [May 16, 2002] When the FCC Knocks on Your Door
  [May 31, 2001] Making the FCC Your Business

Related internet radio broadcast:
  [April 14, 2004] Marlon Schafer at ISPCON and the FCC

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