Expanding FCC Use of Electronic Communications

Although a lot of work has been done over the last few years to incorporate some aspects of our modern communications tools into the workings of the Government Communications Commission, more is needed to slow up the Commission’s reliance on the United States Postal Service (USPS). While I have simply no particular problem with the USPS, the proper thing to do is to embrace electronic technologies and set it as the default for virtually any communication or action by the Commission rate, thereby saving a bit of money and promoting efficiency.

Within fairness, the Commission has been positively trying to move forward on electronic licensing. In December, the Commission’s Wireless Telecoms Bureau released a Public Notice, after seeking public input, announcing that, effective 30 days after publication in the Federal Register, it would implement paperless licensing. Based on an idea raised in Chairman Wheeler’s FCC process reform effort, it was decided which the Commission would stop issuing and mailing paper licenses for present authorizations to licensees and registrants, unless an entity notifies the Commission that it still wants to get official licenses by mail. Below this framework, almost all electronic variations of Commission authorizations stored in two licensing systems (the Universal License System and the Antenna Structure Enrollment System) would be deemed as official Commission documents. Considering that the Commission rate issues almost half a million wireless licenses and authorizations per year in a cost of over $300, 000, this may result in substantial savings. Hopefully, the brand new paperless system will go into impact shortly.

Two latest Commission consent agenda items demonstrate the downside of using traditional mail to communicate with licensees. In one, the Commission voted to reject a broadcast station owner’s request to reinstate a dismissed application mainly because its petition was over four months late. The station argues that its challenge was well-timed because it was filed within 30 days of receiving letter notification from the decision in the mail. Our reason for denying the request was based, in part, on the argument which the information was widely available via a well-timed released public notice and, pursuant to Commission rules, filing deadlines are computed based on the release day of this public notice. If the public notice constitutes official Commission action, then why should the FCC’s Media Bureau mail notifications? And, if such courtesy notifications continue, electronic communications should be used, especially as the Media Bureau is phasing in a new electronic filing system.

In the other case, applications were dismissed for failure to pay the necessary regulatory fees on time. The permit holders claim that they did not get appropriate notifications of the delinquency mainly because letters were sent to the wrong tackles. Once again, this resulted in untimely petitions for reconsideration of licensing choices. The Commission’s reason for denying the request highlights that it is the burden associated with station owners to maintain accurate emailing addresses with the Commission. But the reason why use mailing addresses at all? Perhaps you should use electronic communications for this kind of notifications? That way any communication between the Commission and an outside party could be fully documented, thereby eliminating the majority of, if not all, factual discrepancies.

In fact , the Report on FCC Process Reform, which was publicly released February 14, 2014, suggests that that all Commission Bureaus along with licensing responsibility move to electronic opportinity for licensing and communicating with licensees and the public (see recommendations 2 . six through 2 . 8). And the particular recommendation put the obligation on the FCC’s Managing Director to convene associates from the applicable licensing bureaus to implement. What is the hold-up on finishing this very reasonable review of our licensing and notification processes, and the reason why haven’t other actions been taken to move towards electronic recordkeeping and communications?

Moreover, we should ensure that our overall effort will be sufficiently broad to incorporate all (or at least most) interactions with all those we regulate. For instance, the Nationwide Association of Manufacturers submitted comments within the record in response to the Wireless Community Notice recommending that the Commission make use of electronic notifications when applications are returned. This seems exceptionally fair and should be seriously considered. Our standard position should be that all communications must be done electronically, unless it is absolutely necessary to try and do otherwise.

I understand that will steps will have to be taken to change our own practices to utilize electronic communications. For instance, licensees may have to maintain current email addresses in Commission databases. But , this is no greater a burden on Commission licensees than today’s necessity to maintain mailing addresses.

In the end, the Commission has the responsibility to update its procedures to ensure better interactions with the licensing local community and save taxpayers money. Leader Wheeler set the Commission to the right path on this particular item, but now we need to follow through at a much swifter pace.


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