Either act like every other federal agency or get serious about the rules
It appears that no other federal agency has ex parte rules requiring the outside party to file a summary of "verbal" ex parte contact.
ALL other agencies rely on staff summaries of such meetings filed in a public docket. Abusive parties clearly have an incentive in the present environment to hide, delay or "fuzzify" ex parte contact to put their adversaries at a disadvantage.
If FCC really wants to keep the current unique system, then it should enforce its rules. The present concept of handling enforcement by a polite phone call to the party involved is charming and apparently works most of the time. However, it does not work all of the time. When it doesn't work, there is not present alternative. A very small number of parties continue to be repeat violators with impunity even though almost everyone else is compliant.
There is no written record of ANY enforcement action by the Commission in the ex parte area. Complaints are difficult to file and are dismissed under a "shell game" approach reminiscent of the old, not discredited, process for indecency complaints.
Complaints should be public and should be acted on promptly.
Clarify or revise the reporting obligations of 1.1216 with respect to Commission employees and the public and make sue the clarification or revision is followed.