Date: 2026-08-03 Method: Per the protocol's §12 seed and the M6/GBMT-2 precedent (legal capacity first because it's cheap and slow-burning; demand-side last because it's fastest to legislate but does least to fix the underlying capacity problem) — tested against this filing's actual scorecard results, not assumed.
Note (post-red-team, see ws11-red-team-log.md): the scorecard this sequencing was built from has been corrected since first draft. Structural platform remedies (#8) are no longer the scorecard's dominant, most rank-stable performer — that claim rested on a D-axis score this project never actually verified, and has been walked back. Point 1 below is revised accordingly: it remains a low-cost thing to track, but not because it "won" the scorecard. Point 2's public-media framing is also softened: Finland's counter-example (a formula-based, arm's-length subsidy that was still cut ~96%) means "move funding outside the appropriations cycle" is a necessary but unproven fix, not a solved lesson.
1. Track, don't legislate: structural platform remedies (exogenous) — but treat the coverage claim as unverified
US v. Google's ad-tech remedies are already in motion through the courts, not this policy area's legislative control, and require no new federal action from this filing's perspective. That alone is reason enough to track rather than legislate around it — it costs nothing to monitor. What changed: this is no longer scored as the scorecard's dominant performer; no workstream in this project verified the actual strength or scope of these remedies, and the corrected scorecard reflects that gap honestly rather than assuming a strong effect. A dedicated workstream on US v. Google's actual remedy posture is a prerequisite before this architecture is scored, or sequenced, with any real confidence.
2. Public-media funding mechanism: redesign is necessary, but not proven sufficient — sequence the open question, not a solved answer
The largest swing in the scorecard is still architecture #4 vs. #4b — restoring public-media funding inside vs. outside the annual appropriations cycle — and CPB's dissolution remains the clearest proof in this filing that formula/insulation design alone did not protect it from a determined simple-majority vote. But per the red-team correction, this project's own evidence (Finland's ~96% cut to an equivalently-designed subsidy, and the BBC's licence fee currently under its own unresolved Charter review) means no non-appropriated design has a completed, successful durability track record to point to. The sequencing implication survives in weakened form: specifying a funding mechanism that sits outside the annual appropriations cycle is a necessary design question to resolve before scaling public-media investment, but it should be sequenced as an open research/design question — closely tracking how Denmark's live 2025-26 subsidy-redesign commission resolves it — not treated as a solved prerequisite the way the original draft implied.
3. Pair any demand-side instrument with a distribution-reform component from day one
Vouchers/subscription credits (#5) are constitutionally straightforward and citizen-directed, but two independent randomized free-subscription offers produced minimal activation and no detectable local-news or civic effect. The existing allocation concern remains unmeasured: the studies do not show where voucher dollars would land by outlet or county. If retained, this architecture needs a geographically targeted, experimentally phased pilot that publishes redemption destination and measures reporter/coverage output; it should not be launched on the assumption that lower price creates local-news demand. See §14.
4. Let state-level tax credits keep running as the policy area's real-world laboratory
Four states (CA, NY, IL, NM) have already enacted payroll-tax-credit designs, and Illinois's is the one architecture in this entire filing with actual disbursement data proving the mechanism works at small scale (260+ jobs, 30% to nonprofits, mostly outside the largest metro). This is comparatively cheap, already politically tractable (four states across the political spectrum have passed versions), and generates exactly the kind of real natural-experiment data (uptake rates, eligibility-gap exploitation, geographic distribution) that a federal design should be built from rather than guessed at. Sequence: let 2-3 more state cycles complete before federalizing, using NY's ownership-eligibility loophole (excludes public companies but not hedge-fund owners) as a specific, fixable design flaw to correct before scaling.
5. Deprioritize platform-bargaining-code approaches pending a redesigned distribution formula
The bargaining code (#2) is the scorecard's second most rank-stable bottom performer, for two independent reasons found in this filing: platforms can and do simply exit rather than pay (Meta's Canada and Australia walk-aways cost Meta itself nothing measurable), and where money does flow, it concentrates overwhelmingly in large incumbents (~90% in Australia, per peer-reviewed evidence) — the opposite of what a "save local news" instrument should do. This should not be a near-term legislative priority in its current form. If revisited, it needs a fundamentally different distribution mechanism (a mandatory desert/small-outlet allocation floor, not a negotiate-your-own-deal structure) before it is worth the fragility risk — and the reform coalition's own internal opposition to the JCPA (Free Press, Public Knowledge, both opposing the incumbent-favored design) suggests this redesign work has organic political support waiting to be organized, not just added as an afterthought.
[Verification Phase 2, 2026-08-10 — the redesign this paragraph specifies already exists in law, in two countries, and this filing missed one and under-read the other.] Canada's Online News Act Application and Exemption Regulations (SOR/2023-276, registered 15 Dec 2023) is a mandatory allocation structure, not a negotiate-your-own-deal one: s.9(2) sets the price by formula ("$100 million × CPI x ÷ CPI 2023"), s.10(2) keys distribution to full-time-equivalent original-news-producing employees, s.10(3) caps broadcasters at 30% and the CBC at 7%, s.7 requires a majority of the money to fund local/regional/national news production, and s.4(1)(a) requires a 60-day open call — under which Google "received responses from more than 600 news businesses representing 1435 news outlets" and "did not reject any news business that submitted an attestation" (CRTC 2024-262). Australia's News Bargaining Incentive, finalised 3 August 2026 — this filing's own filing date — doubles the "distribution scheme loading for regional-based journalists, small to medium publishers and media servicing underrepresented communities from 10 to 20 per cent" and adds a grants program for publishers under $150k revenue. moving-targets-log.md caught the Australian change on 2026-08-06 and recorded that it "respond[s] directly to the incumbent-capture critique this filing documented"; nothing downstream moved. The sequencing recommendation ("deprioritize pending a redesigned distribution formula") survives for the US legislative agenda, since no US bill has that formula; the premise that the redesign is hypothetical does not. See steelman-log.md, target B.
6. Treat philanthropy as a pilot/supplement function permanently, never a core-funding assumption
Press Forward and AJP combined are ~55x short of even one year's revenue-loss gap — this is not a scale philanthropy is trending toward closing, it is a standing, structural mismatch. Philanthropy's appropriate sequencing role is what it already does well: funding pilots, pluralism experiments, and specific high-value nonprofit newsrooms (INN's $750M/yr sector total shows this can sustain a real nonprofit-news ecosystem at the outlet level) — never as a line item in any core-funding calculation for closing the desert gap nationally.
One time-sensitivity to carry into whatever sequence is chosen
Ownership concentration is moving in the wrong direction on its own clock, independent of any policy choice here: the FCC's scheduled August 6, 2026 vote will likely formalize case-by-case waivers in place of the hard 39% cap, three days after this research pass. Any sequencing plan that treats "market competitiveness" as a slow-burning, low-urgency track (the way GBMT-2 treated legal capacity as safely deferrable) is wrong for this specific axis in this specific policy area right now — the baseline itself is actively deteriorating on a fast clock, which argues for tracking §7/§5 developments continuously rather than treating the scorecard's snapshot as durable past mid-2026.