CONCURRING STATEMENT OF
COMMISSIONER MARY L. AZCUENAGA

Amendment of the Commission's Procedural Rules
Governing Adjudicative Proceedings

The Commission today amends its procedural rules governing administrative adjudications. I welcome the amended rules as a first step in reforming the Commission's adjudicative process. Some of the amendments seem clearly to be good ideas and the others may be worth a try to help expedite the Commission's adjudicative proceedings. Whether they will result in net benefits remains to be seen. Although rule changes to expedite adjudications are a starting point for improving the adjudicative process, reform ultimately should focus on improving the quality of the adjudicative record and of adjudicative decisions to help ensure that they meet the test of appeal.

I support further examination of the entire process, including how to focus discovery and hearings more precisely on the pertinent facts, and how best to prepare the record for efficient use in formulating reasoned and well supported decisions. I look forward to the next installment of this effort.