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BCNGroup e-Bulletin

 

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.