Using With Legislation

At the same time as Simon Fodden was publishing and Annotation, a group of colleagues and I were in the middle of a series of invited comments to U.S. Federal Communications Commission, about their rulemaking for home Wi-Fi routers. We were using Google docs for mutual editing already, so looked like something worth trying for mutual markup.

To make a long story short, it was excellent. I’m now running permanently with a “Launch Hypothesis” button in my bookmarks bar.

Over and above Simon’s description, the things that stood out for me were:

  • Links to particular annotations as well as to the whole page, such as that takes the reader to an individual annotation by itself. That particular one is Dave Täht’s reply to a question of mine, about a bug that would take a router right out of compliance, a bug which he fixed.
  • A secret feature to show me all my annotations, reached by clicking on the person icon, then on your name. That takes you to a sortable, searchable page of everything you’ve annotated. With my leaky memory, “” is a necessity!
  • Convenient sharing via email, Google+ and the like.

The few things I didn’t like were

  • That many PDFs required postprocessing before you could annotate a particular phrase. There are free postprocessors, as mentioned at but the extra step meant I would have needed to take a copy, as of a particular date.In our case the annotations are to a maintained, versioned, html copy of the Electronic Code of Federal Regulations, so we can annotate the “living” document as of December 30, 2015 and expect the links to stay pointing to the most current version.

All in all, it was an excellent tool for analyzing a proposed bit of rulemaking that had caused great concern in the technical community.

It helped us find what now seems to me to be a drafting mistake, in which the FCC’s proposed language shifts responsibility away from the owners of the devices, who are legally responsible. Instead the FCC proposed to make the hardware manufacturers responsible to keep the owners from changing anything. That unfortunately also prevents the owners of the routers from downloading the available fixes for the compliance bugs! The owners (meaning we) promptly objected.

Hypothesis has been a great help. Now I’m off to discuss some different language to propose to the FCC.

Comments are closed.