STATEMENT OF
COMMISSIONER MICHAEL J. COPPS
Re:  In the Matter of Amendment of the Commission’s Ex Parte Rules and Other Procedural Rules, GC 
Docket No. 10-43; In the Matter of Amendment of Certain of the Commission’s Part 1 Rules of 
Practice and Procedure and Part 0 Rules of Commission Organization, GC Docket No. 10-44
Reform has clearly come to the FCC. In my first week as Acting Chairman last year, I had the 
privilege of addressing the Commission staff on the need to revitalize and reenergize the operations of the 
agency. I said then we must always strive to improve our lines of communication, enhance the level of 
transparency in our work and bring to our daily decisions the kind of openness that gives true credibility 
to everything we do. We have made progress. Today’s presentation makes that clear, even as it makes 
clear that we have much more work ahead in many key areas. I want to thank Mary Beth Richards and 
Austin Schlick for their thoughtful comments, and would particularly like to commend Chairman 
Genachowski for his focus on the issue and also for his good judgment in designating Mary Beth as 
Special Counsel on FCC Reform.  
Today’s two specific Notices of Proposed Rulemaking make an essential down-payment on the 
broader reform agenda. First, at long last, we launch a proceeding to improve the transparency and 
effectiveness of our decision-making process by reforming our ex parte rules. Sound ex parte rules are 
critical to ensuring that everyone has a fair opportunity to respond to the arguments made or positions set 
forth in oral communications with the Commission. We all welcome the opportunity for face-to-face 
meetings with outside experts. That said, we realize that Commission decisions should always rest upon 
the solid foundation of the public interest—not the interests of lobbyists discussed in closed-door 
meetings. Too many times we receive ex parte filings that simply reference that a meeting took place on 
a given topic—without remotely approaching a sufficient level of detail on the arguments or data 
presented to allow the public or interested parties to respond. That is why I am pleased to support 
proposals to make disclosure more robust in more cases, and to begin aggressively enforcing our ex parte
rules.
Second, by proposing revisions to certain procedural and organizational rules, we are taking steps 
to modernize and improve the efficiency of the agency. For example, we propose to delegate authority to 
the expert Bureaus to dismiss or deny procedurally defective petitions for reconsideration of Commission 
action. Steps like these can help provide the full Commission with more time and energy to address the 
many critical issues confronting us.
I would like to thank the staff in the Office of General Counsel and the Office of Managing 
Director for their work on today’s Notices of Proposed Rulemaking. I look forward to working with the 
Chairman and my colleagues on these and further reforms.
I also want to express my appreciation for efforts in Congress led by Representatives Bart Stupak, 
Anna Eshoo and Mike Doyle to reform the work of the agency by proposing to eliminate the statutory 
prohibition on more than two Commissioners talking together outside a public meeting.  My 
experience tells me very clearly that this bar has had seriously pernicious and unintended consequences—
stifling collaborative discussions among colleagues, delaying timely decision-making by the agency, 
discouraging collegiality and short-changing the public interest. This proposed legislation would 
constitute as major a reform of Commission procedures as any I can contemplate. Put that together with 
the work Mary Beth is helping us do and we'd have a record of historic procedural reform here at the 
FCC.