Recognize that comments, replies, and then endless ex partes is a poor way to deal with complex issu
In all rulemakings now, FCC goes through public comments, then reply comments, and then gets in involved in an endless stream of ex parte presentations and some written ex parte filings.
For many complex technical issues, 2 rounds of comments are not enough for convergence of views. Consider the technical side (FDD vs. TDD) of the AWS-3 controversy for example.
Multiple thread in a bulletin board or blog format might be a better way to have an open dialogue with either convergence or narrowing of differences. Moderation by the FCC staff to make sure key issues are addressed would be important.
The current focus on endless oral ex partes puts small firms at a major disadvantage, is slow, encourages abuse of process through skirting ex parte rules, and probably is not a constructive use of the 8th Floor's time.