DISSENTING STATEMENT OF COMMISSIONER JESSICA ROSENWORCEL Re: Establishment of the Office of Economics and Analytics, MD Docket No. 18-3. With this decision the FCC embarks on a big reorganization. Improving the day-to-day function of the agency is a laudable goal. I am hopeful that the new Office of Economics and Analytics will positively contribute to the work of the agency. But I am dismayed that my most basic questions about what this office will entail have not been answered. How many people will the agency have in this office? Are we talking about 50 or 100 or 150? No one will answer. What does it mean to “generally shift the functions” of certain divisions? Does it mean disbanding some we have today? No one will answer. Will we be hiring new experts for this office or simply relying on moving around those we have? No one will answer. This is striking. When I last voted on big institutional changes—the reorganization of our field offices—we had exacting numbers. We knew precisely what these changes would mean for the agency, its staff, and its workload. I think it’s irresponsible to vote on a conceptual reorganization—which is what we have here— without frank information about how we will populate this effort. I think this lack of transparency is problematic—for the staff of this agency and the work it does. Having been refused this basic information, I dissent. That does not mean I lack thoughts for what values should guide this office as this agency moves ahead. In fact, I have three. First, economic analysis plays an important role in all of our work. But we need to be mindful that we have legal duties that can be at odds with simple cost-benefit analysis. The charge to ensure universal service in our most rural communities—where populations are sparse and the cost of infrastructure is high—do not easily fit through this prism. Likewise, we have duties to ensure broader access to modern communications through the Americans with Disabilities Act and the 21 st Century Communications and Video Accessibility Act. How we navigate these efforts in light of this office deserves continued attention and vigilance. Second, we need to put a premium on peer review. Rigorous peer review of scientific and economic work has been encouraged and even required since President George W. Bush was in the White House. The FCC should not be relying on studies that do not feature peer review. We need to commit to this course right here and right now because it is unacceptable that so much of the economic work of this agency during the past year was not subject to any standard of peer review. Third, we need more transparency. We need to be honest about how much of the economic data presented to the FCC is advocacy. We want to avoid the risk of relying on numbers masquerading as fact when they simply add up to an effort to champion a desired outcome. There’s a simple remedy. Anyone who appears before our oversight committee in the United States House of Representatives must file a Truth in Testimony disclosure. That disclosure asks something simple—who are you representing? We should ask the same of those who put forward economic studies that are filed in our proceedings.