{"id":38035,"date":"2025-06-10T21:22:31","date_gmt":"2025-06-10T21:22:31","guid":{"rendered":"https:\/\/publicknowledge.org\/?p=38035"},"modified":"2025-06-10T21:22:32","modified_gmt":"2025-06-10T21:22:32","slug":"is-the-federal-communications-commission-out-of-commission","status":"publish","type":"post","link":"https:\/\/publicknowledge.org\/is-the-federal-communications-commission-out-of-commission\/","title":{"rendered":"Is the Federal Communications Commission Out of Commission?"},"content":{"rendered":"\n

Last week, Commissioner Nathan Simington of the Federal Communications Commission unexpectedly announced<\/a> that Friday, June 6, would be his last day at the agency. Almost immediately after, Commissioner Geoffrey Starks, who had previously announced his intention to leave the same agency before the next FCC Open Meeting on June 26<\/a>, announced that he, too, would depart<\/a> on June 6. Since former FCC Chairwoman Jessica Rosenworcel previously left (as is tradition) in January when President Trump was inaugurated, that leaves just two members of the five-member Commission \u2013 Chairman Brendan Carr and Commissioner Anna Gomez. Which means, for the first time since anyone can remember (perhaps ever), the FCC lacks a legal quorum to do business.<\/p>\n\n\n\n

So what happens? Does that mean the FCC just shuts down? Does the agency proceed on autopilot? Turns out, like so much these days, the answer is both complicated and unclear. But here\u2019s an analysis of what we do<\/em> know based on the existing statutes, regulations, and relevant case law.<\/p>\n\n\n\n

What Do the Statutes and Regulations Say?<\/strong><\/p>\n\n\n\n

Even these days, perhaps out of habit, I start out with the actual text of the law. Section 154(h)<\/a> of the Communications Act says: \u201cThree members of the Commission shall constitute a quorum thereof.\u201d That seems fairly straightforward. If you don\u2019t have a quorum, you can\u2019t do business. Two is less than three, so the Commission has no quorum and can\u2019t do any business. Simple, right?<\/p>\n\n\n\n

But Section 155(c)<\/a> gives the Commission the authority to delegate most of the routine functions (and some non-routine functions) to a variety of employees, individual commissioners, or a \u201cpanel of Commissioners.\u201d The Commission has therefore delegated a good deal of authority \u2013 particularly on technical and routine stuff, which is actually the bulk of what the FCC does \u2013 to the various bureaus and offices that make up the agency. In addition, Rule 0.212<\/a> allows the Chair (or acting Chair) to create a \u201cBoard of Commissioners\u201d of all the Commissioners present and able to act (here, Chairman Carr and Commissioner Gomez). The rule delegates to this \u201cBoard of Commissioners\u201d authority to do everything the actual Commission can do, except<\/em>: <\/p>\n\n\n\n

(a) reach the final merits on a rulemaking or adjudication; <\/p>\n\n\n\n

(b) decide a petition for reconsideration on an action by the real Commission; and, <\/p>\n\n\n\n

(c) resolve an application for review of an order from a bureau or office. <\/p>\n\n\n\n

This last item is fairly important, as Section 155(c) also says you cannot appeal a decision of the bureau unless you appeal to the real, fully staffed Commission and get a result of the real Commission, at which point you can appeal the decision of the real Commission to a real federal court of appeals.<\/p>\n\n\n\n

So question resolved, right? The FCC chugs along doing its usual stuff, but can\u2019t create (or repeal\/modify) any rules or make a final decision on an enforcement action. But usual stuff like certifying that your computer doesn\u2019t generate harmful interference, or issuing license renewals or processing satellite applications or fast-tracking copper loop retirements go on as usual.<\/p>\n\n\n\n

Of course not.<\/em> That would be way too easy. Now we look at case law.<\/p>\n\n\n\n

How Does the Case Law Make This Complicated?<\/strong>

The question boils down to this: When the full Commission delegates authority, does it do so by making the bureau\/Board of Commissioners an agent<\/em> of the Commission, or does it act by its own intrinsic power to delegate and confer authority under the statute? If the bureau is merely an \u201cagent\u201d of the Commission, then its power vanishes when the quorum (and, therefore, the power of the Commission) vanishes. But if Section 155(c) gives the Commission the power to appoint someone and confer on them independent authority (subject to review, until revoked), does the authority it delegated stand? Did it transfer a little bit of its magic power, like Sauron putting power into the One Ring so that it still works even if Sauron is vanquished? Or is the full Commission like the One Ring, and when it gets destroyed, Sauron (the bureaus, offices etc.) then dramatically slides into the abyss with it?<\/p>\n\n\n

\n
\"\"<\/figure><\/div>\n\n\n

To try to provide an example that makes sense to non-geeks: When my wife fell ill, I had power of attorney to make health and financial decisions on her behalf. When she died, my POA became useless. Why? Because there was no longer a live person for whom I was acting. I had to probate the will and become administrator of the estate to do things like cancel her credit cards. This is an example of \u201cagency.\u201d The authority (power of attorney) only lasts as long as I am the agent of the person with the authority. When that person is gone, I am no longer their agent and have no authority.<\/p>\n\n\n\n

By contrast, once power was delegated to me by the will, it was a permanent delegation. Sure, she made that delegation when she was alive (and contingent on a specific future event). But once the delegation went into effect, it persisted permanently. <\/p>\n\n\n\n

There isn\u2019t a lot of case law on the subject that I could dig up in the five minutes I devoted to this topic. There aren\u2019t a lot of independent commissions that require a quorum. Back when we had a functional government (you young \u2018uns don\u2019t know what I\u2019m talking about, but trust me) the president and Congress (even when they belong to different parties) tried very hard to keep these agencies functioning for the good of the country. No, stop laughing! I mean it! This used to be\u2026 sigh\u2026<\/p>\n\n\n\n

Anyway, the cases I have relate to the National Labor Relations Board, an independent commission with a somewhat different governing statute.<\/p>\n\n\n\n

In a 2009 case in front of the D.C. Circuit Court of Appeals, Laurel Baye Healthcare v. NLRB<\/em><\/a>, the D.C. Circuit went with the “agency theory.” Once the NLRB lost its quorum, the parties to whom it had delegated authority also<\/em> lost their power. They were no longer agents of an authorized NLRB, making all their decisions invalid.<\/p>\n\n\n\n

In 2010, however, the U.S. Supreme Court decided New Process Steel v. NLRB<\/em><\/a>. The Supreme Court took this up in part because the D.C. Circuit’s opinion was at odds with seven other courts of appeals that had decided similar cases and concluded that the delegation continued despite loss of a quorum. New Process Steel<\/em> involved a different sort of delegation than that at issue in Laurel Baye<\/em>. In New Process Steel<\/em>, the Court addressed the way the five-member NLRB had tried to address the loss of a quorum before it occurred. Aware that it was about to lose its quorum, the five-member NLRB delegated its authority to a panel of three members (which their statute allowed) and relied on the additional provision that when the NLRB delegates to a three-member panel, two members of that panel shall be a quorum for doing business under that delegation.

In New Process Steel<\/em>, the Supreme Court reached the same result as Laurel Baye<\/em> with regard to the issue at hand \u2013 that when there was no three-member quorum of the NLRB, the two remaining members of the three-member panel lost the authority to act. However,<\/strong> it did not adopt the reasoning of Laurel Baye<\/em>. It relied on statutory language that said the NLRB must maintain a quorum of three \u201cat all times,\u201d which Section 154 does not<\/em><\/strong> say. The Court then gives this rather puzzling analysis of Laurel Baye <\/em>in a footnote:<\/p>\n\n\n\n

\n

\u201cNor does failure to meet a quorum requirement necessarily establish that an entity’s power is suspended so that it can be exercised by no delegee. The requisite membership of an organization, and the number of members who must participate for it to take an action, are two separate (albeit related) characteristics. Thus, although we reach the same result, we do not adopt the District of Columbia Circuit’s equation of a quorum requirement with a membership requirement that must be satisfied or else the power of any entity to which the Board has delegated authority is suspended.\u201d<\/p>\n<\/blockquote>\n\n\n\n

So was the Supreme Court rejecting the Laurel Baye<\/em> agency theory or just not deciding it? The D.C. Circuit addressed this, sort of, in a later case called UC Health v. NLRB<\/em><\/a>. That case involved yet another different set of facts having to do with the delegation to regional offices (a different provision of the NLRB statute). Here, the D.C. Circuit relied on Chevron<\/em> to agree with the NLRB’s construction of the statute that the delegation persisted even if the Commission did not have a legally appointed quorum (over the dissent of Judge Laurence Silberman). Normally, this would be binding. But not only did Loper Bright<\/em> eliminate Chevron<\/em> deference in cases of law (although, as the Supreme Court just showed in Seven County Infrastructure Coalition v. Eagle County, CO<\/em><\/a>,<\/em> whether the agency gets deference really depends on if the panel likes the outcome), it also stated that if a question resolved under Chevron<\/em> ever came up again, the reviewing court should ignore the previous result and make its own analysis. So the analysis in UC Health<\/em> doesn\u2019t even have precedential value.<\/p>\n\n\n\n

So where does that leave us?<\/p>\n\n\n\n

Totally lost.<\/p>\n\n\n\n

What\u2019s My Best Guess?<\/strong><\/p>\n\n\n\n

There is theory and case law to support both interpretations. Either the FCC must have a quorum for any part of it to function \u2013 including the Bureau’s delegated authority as an \u201cagent\u201d of the Commission \u2013 or proper delegations under Section 155(c)<\/a> remain in force because they complied with the statute when made and there is no separate \u201cagency\u201d required. The statute itself invests the delegee with authority (assuming the delegation is by a lawfully constituted Commission) <\/p>\n\n\n\n

I generally think that the FCC can still operate under delegated authority \u2013 but it\u2019s a very<\/em> weak lean. I think the combination of the language of the Supreme Court in New Process Steel<\/em>, combined with the differences in language between the NLRB statutes and the FCC statutes, leans toward the \u201conce lawfully delegated by a proper Commission, it stays properly delegated.\u201d But I can’t rule out the alternative theory. In practical terms, people generally want the FCC to keep renewing licenses, processing discontinuances, etc., so no one really has incentive to challenge most actions on delegated authority.<\/p>\n\n\n\n

Still, as Echostar made clear in its recent filing<\/a> in the proceedings attacking various licenses, big things done at the Bureau level are very likely to be challenged. So I would expect big things like the pending Paramount\/Skydance merger to wait, as will the license cancellations Echostar is protesting. Things might also get a bit tricky if the FCC tries to actually<\/em> enforce anything or to protect consumers in some way. <\/p>\n\n\n\n

I also am not sure about the upcoming June 26 Open Meeting agenda<\/a>. Two of the items, although non-controversial, are final rulemaking Orders \u2013 something even Rule 0.212 prohibits. The other item is a Notice of Proposed Rulemaking, which is OK under 0.212 but what happens if 0.212 is not good law and the actions of the Board of Commissioners is invalid because no quorum of three? The FCC is obligated by law to have a meeting once a month (155(d)), so something<\/em> should happen. Of course, Chairman Carr could call the meeting, find no quorum, and send everyone home.<\/p>\n\n\n\n

Even Chairman Carr seems none too sure<\/a> of what will happen if Olivia Trusty isn\u2019t confirmed by the June 26 meeting. Given all this, I think I will let the Chairman have the last word:<\/p>\n\n\n\n

\u201cBut, as the saying goes, the show must go on\u2026 There\u2019s a lot of time between now and our scheduled June 26 Commission meeting. So I wanted to lay out a couple of items that I would like to get done at the meeting if we can. Stay tuned on that front. What does he mean by that?  <\/em><\/p>\n\n\n\n

I just said stay tuned. We always make a final decision about the Commission meeting and its agenda closer to the meeting date. We will do so again here.\u201d<\/p>\n\n\n\n

Or, more succinctly, who knows?<\/p>\n","protected":false},"excerpt":{"rendered":"

With the agency now down to only two members, what happens next isn’t clear.<\/p>\n","protected":false},"author":14,"featured_media":37161,"parent":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[5],"tags":[],"class_list":["post-38035","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-insights"],"acf":[],"yoast_head":"\nIs the Federal Communications Commission Out of Commission? - Public Knowledge<\/title>\n<meta name=\"description\" content=\"For the first time that anyone can remember, the agency lacks a legal quorum to do business.\" \/>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/publicknowledge.org\/is-the-federal-communications-commission-out-of-commission\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Is the Federal Communications Commission Out of Commission?\" \/>\n<meta property=\"og:description\" content=\"For the first time that anyone can remember, the agency lacks a legal quorum to do business.\" \/>\n<meta property=\"og:url\" content=\"https:\/\/publicknowledge.org\/is-the-federal-communications-commission-out-of-commission\/\" \/>\n<meta property=\"og:site_name\" content=\"Public Knowledge\" \/>\n<meta property=\"article:published_time\" content=\"2025-06-10T21:22:31+00:00\" \/>\n<meta property=\"article:modified_time\" content=\"2025-06-10T21:22:32+00:00\" \/>\n<meta property=\"og:image\" content=\"https:\/\/publicknowledge.org\/wp-content\/uploads\/2024\/08\/Digital-Divide-1440x720.png\" \/>\n\t<meta property=\"og:image:width\" content=\"1440\" \/>\n\t<meta property=\"og:image:height\" content=\"720\" \/>\n\t<meta property=\"og:image:type\" content=\"image\/png\" \/>\n<meta name=\"author\" content=\"Harold Feld\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"Harold Feld\" \/>\n\t<meta name=\"twitter:label2\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"9 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\/\/schema.org\",\"@graph\":[{\"@type\":\"Article\",\"@id\":\"https:\/\/publicknowledge.org\/is-the-federal-communications-commission-out-of-commission\/#article\",\"isPartOf\":{\"@id\":\"https:\/\/publicknowledge.org\/is-the-federal-communications-commission-out-of-commission\/\"},\"author\":{\"name\":\"Harold Feld\",\"@id\":\"https:\/\/publicknowledge.org\/#\/schema\/person\/b99590cf56e076e16a21ef78eab7e144\"},\"headline\":\"Is the Federal Communications Commission Out of Commission?\",\"datePublished\":\"2025-06-10T21:22:31+00:00\",\"dateModified\":\"2025-06-10T21:22:32+00:00\",\"mainEntityOfPage\":{\"@id\":\"https:\/\/publicknowledge.org\/is-the-federal-communications-commission-out-of-commission\/\"},\"wordCount\":2034,\"publisher\":{\"@id\":\"https:\/\/publicknowledge.org\/#organization\"},\"image\":{\"@id\":\"https:\/\/publicknowledge.org\/is-the-federal-communications-commission-out-of-commission\/#primaryimage\"},\"thumbnailUrl\":\"https:\/\/publicknowledge.org\/wp-content\/uploads\/2024\/08\/Digital-Divide.png\",\"articleSection\":[\"Insights\"],\"inLanguage\":\"en-US\"},{\"@type\":\"WebPage\",\"@id\":\"https:\/\/publicknowledge.org\/is-the-federal-communications-commission-out-of-commission\/\",\"url\":\"https:\/\/publicknowledge.org\/is-the-federal-communications-commission-out-of-commission\/\",\"name\":\"Is the Federal Communications Commission Out of Commission? 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