Proposal
to the FCC
This proposal replaces the complaint made to the Inspector General’s office
(Draft
Sunday, November 23, 2003)
Several
technology company management level officials and board members have recently
talked about a required "educational process" needed to help the FCC
understand the current capabilities that are to be derived from commercial
taxonomy technology. Over the next 8
weeks, several demonstration of this capability will be contributed at no
cost. A follow up project could start
in January 2000.
It
is contemplated that a one-year contract with George Washington University
would fund university participation and objective facilitation of Industry
contributions to Impact and to other similar government agency projects. The
university-based contract, if approved, is to be managed for under
$400,000.
Industry
leaders are willing to participate in such a project as a means to advance high
quality commercial technology in a systemic fashion. This course of action is a reasonable response to a noticed
variation between the FCC Impact Business Case and the FCC Impact system
currently designed and being developed.
The variation has been the subject of a private study that has concluded
that a degree of waste and fraud is detectable at the FCC in the context of the
FCC Impact project. No fault is placed
on the BearingPoint contractor.
The
OntologyStream Inc lead research group has argued that Industry benefits by
supporting the demonstration of capabilities that, while being mature, are not
being used in government regulatory agencies due to cultural
considerations. The specific nature of
the cultural consideration varies.
At
the FCC, the concern is that privileged deliberative processes might be
revealed after the fact. Legal interpretation needs to be developed in an
environment where later interpretations are in fact minimized. This is understandable. However, the BearingPoint Business Case for
the Impact project makes the case that there is an efficiency gap at the FCC that
can be closed by implementing high quality document management practices with
selective workflow and knowledge management.
A substantial budget was approved based on this Business Case. As part of the expenditure form this budget,
the OntologyStream Inc lead research group was contracted to provide expert
advise.
OntologyStream
concurs with BearingPoint, while providing clear evidence that the
implementation process managed by the FCC is deeply flawed. This evidence is contained in a Waste Fraud
and Abuse complaint. We assume that positive steps will be made to eliminate
the causes of waste of budget authority and fraudulent representation about the
fidelity of the current software architecture and data model to the Impact
Business Case.
The
OntologyStream Inc research group argues that limiting cultural barriers are
well understood within the communities of practice at the FCC, and that there
is a willingness and ready audience for mature technology as conceived in the
Impact Business Case. Concern over the
cost of this technology is eliminated by the proposal offered by OntologyStream
research group. Any concern about the
actual capability of the technology will be eliminated by the demonstration of
taxonomy generation capability currently being developed using an automated web
harvest of 40,000 documents posted by the FCC since 1997.
It
is requested that a stop work order imposed by the FCC on the evaluative work
by OntologyStream be rescinded, the old contract terminated, and that a new
subcontract be made to OntologyStream for the completion of work envisioned by
BearingPoint Impact manager, Ms Wendy Carr.
Under
this new contract, OntologyStream Inc will establish a research center at
George Washington University to receive taxonomy, knowledge management and
ontology software and methodology.
During the course of the Impact pilot, this research center will work to
inform the FCC staff about how to use software contributed by Industry for the
demonstration period.
Industry
agrees that very low cost evaluation should occur within this educational
environment.
Technology
company management level officials and board members are in agreement, in
principle, that this university based research center would make a substantial impact
on informational transparency within communities of practice in the Federal
regulatory agencies (FCC, FTC, etc).
The agreement extends from a minimum of 7 separate corporate entities,
including several that are highly invested in by Army Intelligence (General
Alexander) and CIA (In-Q-Tel).
We
also argue that the use of this advanced capability is mature and would be
deeply appreciated by the skilled lawyers and technical editors at the FCC.