A Modified Delegated Authority Proposal

I have made the case previously that the Commission delegates way too many substantive decisions to Bureau staff, usurping the role and obligations of duly appointed and confirmed Commissioners. Consider that in 2016 I only voted on 167 items, but almost nine times as many were decided on delegated authority. The heart of my revised delegated authority proposal is an attempt to achieve balance between the need to allow Commissioners to have greater say in the workings of the Commission and preventing process abuses and unnecessary delays.

Here are its main components:
Advanced Warning: Consistent with my previous recommendation, except for the most routine matters, Commissioners should be provided no less than 48 hours to review an item that is to be decided by Bureau staff under delegated authority.
Request by Two or More Commissioners: On any given matter, it is possible that any one Commissioner could be troubled by the substance or process of an item.
Time Constraint: A concern was raised that having two Commissioners as the proper threshold may not necessarily provide a sufficient barrier to excessive or needless delays.
Automatic Approval if Delayed: Under my proposal, in those instances (if ever) when a requesting office does not vote by the deadline, the item would be – at the Chairman’s prerogative – either released as approved by the full Commission (assuming the other offices voted to approve) or sent back to the Bureau for immediate issuance on delegated authority.