Complaint
about FCC funding of improper IT in the FCC
Events
related to the Complaint
Letter
(edited copy below) to
H.
Walker Feaster III, Inspector General (Monday November 24, 2003
GAO FraudNET filing (Tue Dec 9 17:33:49)
GAO FraudNET response with GAO claim # 44777
Dec 11th 2003
InOrb
Technologies Web site opened (www.InOrb.com)
(Dec. 15th 2003)
Senator
Warner and the FCC reject the complaint (Dec. 16th 2003)
GAO FraudNET response
(March 5th, 2003)
Monday,
November 24, 2003
H.
Walker Feaster III
Inspector
General
Federal
Communications Commission
Mr.
Feaster,
I
wish to file a grievance over the treatment that I received last week by FCC
managers x and y in their role in managing the development of the FCC q document
management system.
In
early October, I was invited by a research institute at George Washington to
advise the FCC on the development of taxonomy as part of the Impact pilot.
After a discussion with the lead FCC contractor for the q project, r, I made a 12
week contracted commitment. Consistent
with an approved Statement Of Work (SOW), I initiated work processes that
involve discussions with Industry and Academia. The r manager was informed of this work process.
I
sought approval to contract with Dr. m to assist in the development of polling
instrumentation as part of the process of reifying machine-generated
(algorithmic) subject matter indicators.
Dr m and I arranged technical and scientific discussions and associated
work schedule so as to provide the leading-edge advice and technology
demonstrations in service of the stated SOW.
Part
of the task was to evaluate and bring to the FCC team's attention the relevant
technologies and methodologies related to the automation of taxonomy (subject
list) development and management, both as classification/retrieval metadata for
document management and as enhancement to push/pull knowledge portal
capabilities.
In
four weeks of effort, I brought the q team into contact with important and
relevant technology and methodology.
Dr. m began the development of polling methodology suited to the FCC
taxonomy reification task. Five
meetings occurred with r and/or the FCC in support of this work on polling
methodology.
The
discussion with management, founders and board members in several technology
companies, lead to a serious commitment to proved steep discounts in evaluation
deployments of technology. The
commitment recognizes that these evaluating deployments are needed because the
FCC staff members are largely un-informed about the nature of 2003 knowledge
representation and knowledge management commercial off the shelf software
systems.
Industry
leaders and relevant scientists support the development of a cultural shift
into an information flow architecture reflecting r’s FCC approved Business
Case.
We
understand through private conversations, with FCC personnel, that the FCC
upper management is engulfed in a controversy over just these types of
issues. We know a similar controversy
to be occurring internally within the FTC.
As
my work unfolded, a specific core issue became how subject matter indicator
taxonomy might be used within the current document management system.
The
current AS-IS model, produced by the OntologyStream Inc research group,
describes how the FCC management of currently being deployed document
management system makes no responsible attempt to accommodate any use of
subject matter taxonomy – in spite the clear argument made in the Business
Case.
The
r project manager agrees with this assessment.
Her agreement can be established by interview and is evidenced by e-mail
from her to me.
On
Wednesday, November 19th, 2003, x indicated to the r project manager
that the OntologyStream Inc research group’s work was to be stopped. This was
after a conversation she had with y.
We
claim that this conversation established intent to de-fraud the American People
by purposefully stopping a disclosure that the Impact project would not have
the advertised capability – as stated in r’s FCC approved Business Case. The conversation also established intent to
waste government resources by not allowing a simple adjustment in design and
functionality that was specifically suggested by the OntologyStream Inc
research group.
The
conversation also abused Dr. Prueitt directly through an exercise of delegated
regulator power. The action following
the discussion infringed on Dr. Prueitt’s Constitutional rights to pursue a
lively hood based on the application of objective science to knowledge
management issues.
This
infringement contributes to an atmosphere of tacitly acknowledged inhibition to
any contractor or subcontractor who would suggest that Information Technology
contracts, such as the one justified by Business Case, are not what are
indicated in the Inspector General’s FCC contract’s audit procedures.
A
specific set of conversation behaviors by the two programmers, xz and zy, and
by the IT project manager, xy, evidence the consequences of this pattern of
abuse. The conversation behaviors
include habitually deferring any question that would expose the limitations of
the software, the selected document management system, data model. The deferring behavior took two forms, (1)
actually deferring all, or most, simple questions about the data model for a
later date (We conjecture that this was under specific advise from the FCC
management), (2) actually answering a different question that the one asked and
acting as if this was the correct answer.
This conversation behavior is endemic and not natural.
We
suggest to the IG that the deception intended and achieved is documented and
can be demonstrated by interviewing the computer programmers who are on the
team. November 14th, 2003
e-mail from the project manager to Dr. Prueitt describes this behavior, as does
hand written conversational notes between the manager and Dr. Prueitt made
during the core members team meeting on November 6th, 2003. (Both of these documents can be obtained,
from Dr. Prueitt, via IG subpoena.)
We
claim that the OntologyStream Inc lead research group communicated scientific
and technological information to the FCC.
On hearing this information, the research group was ordered to stop
work.
The
information exposed a rather large difference between what was the approved
purpose (as described in the Impact Business Case) and what the FCC Impact team
is actually developing. Thus, we claim,
that the decision to order the contractor to stop work was based on a need to
inhibit the use of critically important capability – and that this capability
is the corner stone of Business Case that justified the approval of the FCC
budget.
If
we understand the over all budget (3.1 - 3.8 million) the total cost of
receiving the best possible advise on available taxonomy development technology
and methodology is 1.7 % of the total budget.
But the advice can be shown to leverage the entire project. The OntologyStream Inc research group’s task
was to provide the best advise based on the research group’s deep professional
experience and personal contacts within the technology and scientific
community.
Further,
rather than address the real differences between what was proposed and approved
and what is on the path to being developed and deployed, the FCC acted
deceptively to suddenly terminate the OntologyStream Inc effort. The
termination of work was made in a fashion that reflects poorly on the FCC
contracting process and on the FCC’s public commitment to honest debate and
respect for scholarship and academic workers.
An
investigation into the cultural relationships between (1) the research library,
and digital services at that library, and (2) the Impact project team will
demonstrate a pervasive cultural barrier blocking the implementation of subject
matter taxonomy as metadata. Long-standing conflicts characterize this cultural
relationship.
We
request an internal investigation about the details related to the stop work
action issued by the FCC on the work of Dr. Paul Prueitt and his research
group.
The
social contract between the Government and Its People can be breached by
arbitrary actions that hides the mismatch between what are approved contractual
expenditures and what will be delivered in services.
As
for the long-term root of the claimed waste, fraud, and abuse this root should
be immediate investigated and steps made to remediate the cultural behaviors
that allow the waste, fraud and abuse to be repeated.
Dr.
Paul S. Prueitt
Research
Professor
The
George Washington University
Founder
and Director, (1992) BCNGroup.org
Founder,
(2000) OntologyStream Inc
Knowledge
Scientist
Cell:
703-981-2676
paul@ontologystream.com