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Independent federal agencies face pressures from both the public, industry, and Congress to clearly establish and articulate their regulatory goals, implementation processes, and evaluation protocols. Many of these agencies are beholden to Congress to secure and maintain the funding and authority to carry out policy initiatives. This article makes an argument for a framework for communicating agency needs, initiatives, and progress to stakeholders for improved efficacy. The proposed framework is illustrated using the case study of the Federal Communications Commission (FCC) and the Secure and Trusted Communications Network Act of 2019 (STCNA), colloquially known as “Rip and Replace.”
The STCNA prohibits the use of federal funds to obtain communications equipment or services from a company that poses a national security risk to U.S. communications networks. It also provides funding to remove this “covered equipment.” The FCC oversees this program. The program is ongoing. In 2024, it was discovered that the covered hardware had been used by adversarial governments to conduct a cyber espionage campaign on U.S. telecommunications networks for years. The equipment in question was still used in U.S. telecommunications networks due to delays in the implementation of “Rip and Replace” and a funding shortage.
This project explores how the FCC communicates regulatory goals, justification of authority, funding needs, evaluation protocols, and required adjustments in the process of implementation in the case of the “Rip and Replace” initiative. The case study is developed based on an analysis of the FCC’s public-facing reporting of the goals, progress, challenges, and opportunities of the “Rip and Replace” initiative. The case study includes a historical review of the events leading up to the STCNA and through the implementation of the initiative. It also includes a textual analysis of the policy documents related to the implementation of the program. Data collected includes the text of Secure and Trusted Communications Network Act of 2019, FCC press releases, Congressional testimony from FCC officials, and published reimbursement reports from industry providers carrying out the removal, disposal, and replacement of the covered equipment.
Preliminary findings suggest that shifting stakeholder goals can impact an agency’s adaptability. Issues involving an unexpected request for increased funding seem to have a particular element of tension. In the case study, regardless of a lack of funding, the agency is still expected to carry the responsibility for the policy’s success or failure.
The case study illuminates how struggles with a mutual understanding of the complexity of an issue and the organizational requirements to accomplish the policy goal can diminish the efficacy of the agency and the policy. A communications framework to guide effective communications between the agency, Congressional leaders, and the public would reduce this friction and improve policy outcomes. On an organizational level, such a framework requires connection to communities, a proactive data management strategy, and an adaptive approach to management across the FCC’s multiple bureaus.
It is expected that the results of this ongoing research may have interesting applications for other independent federal agencies beyond the FCC.