As discussed in many prior posts here, OMB’s 2020 WIFIA FCRA Criteria are seriously and fundamentally flawed. Now that the process of replacing these invalid restrictions on WIFIA and CWIFP statutory eligibility has moved to the narrative stage, the current Criteria pose a new challenge: What is their narrative? To make the case that something needs to be replaced, you start by describing that thing and only then explain what’s wrong with it. We know what the Criteria do — restrict loan eligibility — but on exactly what basis with respect to any law, principles or logic? In a long-read essay format, you can demonstrate that the Criteria are based on confusion, dishonest agendas and logic-free thinking. I think I’ve done that. But for a pro-and-contra narrative debate in an attentionally challenged forum, that approach won’t work. It’ll lead very quickly to ‘argument from authority’ territory, and the Criteria’s author is in fact the ultimate authority in this case. Case dismissed — next.
Instead, it’s not only necessary to anchor the Pro-Eligibility Narrative in FCRA law, principles and logic, but to describe the Pro-Criteria Narrative as if they were trying in good faith to do the same. Then you can show — ideally, in rapid-fire narrative style — that the Criteria simply misunderstood the relevant law and principles, and that your alternative is obviously better.
You’d think there wouldn’t be any need to go full straw man on this one. The current Criteria were established by a precise Congressional Directive that directs OMB and WIFIA to use FCRA law and the budget principles of the 1967 Report, and to publish the outcome in the Federal Register. We’re not exactly working with a WaPo op/ed here. A simple summary of the current Criteria as published ought automatically to be the Pro-Criteria Narrative case in the context of the law and principles we want to talk about, right?
Not quite. The Federal Register publication refers to FCRA law and budget principles often enough, and the text has that measured tone of Serious Bureaucratic Expostulation. But after nearly a year of looking at the Criteria and everything about the issue I can find, I still have no idea what exactly they’re saying. I know their conclusions (effective ineligibility for a wide swath of otherwise eligible loans, especially at CWIFP), the fact that those conclusions are being used at face value (e.g., CBO scoring), and that the whole mess is hopelessly wrong. Drafting a Pro-Criteria narrative that sounds at least a little bit coherent is necessary to avoid immediate ‘dismissal by authority’ before the debate even gets started, as noted above. But I’m finding the task very challenging.
I tried one approach in the super-short narrative draft a few days ago, but the ‘therefore must’ phrase connecting budgeting for the cost share asset with that of the loan now seems so glaringly unsupported and logic-free as to suggest the working of some type of transcendent budget wisdom that is beyond explanation to mere mortals. Don’t want to go there. A mention of a connection that the Criteria do in fact rely on is needed for a Pro-Criteria narrative. But the publication never explicitly says anything about it and assigning specific words to convey the idea as if it were credible is fraught with risk. So far, the right words fail me.
So, I’ve tried another approach — just let the Criteria speak for themselves. In this approach, the Background section of the publication is the Pro-Criteria Narrative, in the authority’s very own words, no more nor less. It’s not a snappy summary, but fortunately the Background section is only about 8 lines long, so possibly amenable to narrative treatment for the slightly more attentionally abled, which is where one hopes technical this issue will be considered anyway. The approach goes through the section line-by-line and presents the Pro-Eligibility Narrative in the form of individual line responses with a short summary conclusion. Here’s the first attempt [updated 10052023]:
WIFIA-FCRA-Criteria-Background-Section-Line-by-Line-Review-Version-1.1-10052023-InRecap