Development of the Consolidated Licensing System Workshop
Federal Communications Commission
May 6, 2010
10:00 am to 1:00 pm
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-10-596A1.doc and
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-10-557A1.doc
10:00 a.m. Welcome and Introductory Remarks
Mary Beth Richards, Special Counsel to the Chairman for FCC Reform
10:20 a.m. - 1:00 pm Roundtable Panel -
Moderator Andrew C. Martin, FCC Chief Information Officer
Allison Ellis, Ericsson, Director, Regulatory Policy
Christopher Imlay, General Counsel, ARRL, the national association for Amateur Radio
Brian Higgins, Wilkinson Barker Knauer LLP Partner
Chris Duffus, Spectrum Bridge, Inc., CFO
Christopher Bjornson, Steptoe & Johnson LLP FCBA Access to Government
Connie Durcsak, PCIA, Senior Director, Industry Services
David Redl, CTIA, Director, Regulatory Policy
Donald Vasek, UTC, Director Spectrum Services
John Garziglia, Womble Carlyle Sandridge & Rice, PLLC
Joan Griffin, Kelley Drye and Warren, LLP, Of Counsel
Joseph Davis, Chesapeake RF Consultants LLC, President; Member AFCCE
Mark Brennan, Hogan Lovells US LLP
Katie Venticinque, FAA, Aeronautical Info Specialist
Linda Braboy, Bennet and Bennet, and Rural Telecom Group (RTG)
Mark Gibson, Comsearch, Director, Regulatory Policy
Peter Nordby, Sitesafe, Inc., representing APCO
Peter Tannenwald, Fletcher, Heald & Hildreth, P.L.C.
Thomas S.Dombrosky Jr, Wiley Rein LLP, Engineering Consultant
Troy Langham, Clear Channel Communications/Radio, Sr. FCC Engineer
FCC Representatives:
Anthony Serafini, OET
David Ward, PSHSB
James Brown, WTB
Jim Bradshaw, MB
Hossein Hashemzadeh, MB
Jim Brown, MB
Kathleen Campbell, IB
Lisa Scanlan, MB
Thomas Nessinger, MB
Thomas Sullivan, IB
Wayne McKee, MB
William Dever, WCB
The Panelists in the Roundtable will be asked to comment on the following topics and questions, which cover electronic filing and correspondence, the application process, data, phased-in implementation, and exceptions.
ELECTRONIC FILING, CORRESPONDENCE AND NOTIFICATIONS
1. What are the major concerns raised if the Commission were to mandate electronic filing where it is not already required? As the Commission recognized in its Ex Parte proceeding, "in some cases, electronic filing is not possible without undue hardship because the person making the oral ex parte presentation does not have access to a computer or the Internet." Would these concerns also arise if the Commission mandated electronic filing of all CLS forms? If so, please provide details, including specific examples of undue hardship.
2. In light of those concerns, should the Commission maintain an option for filing application forms either manually or telephonically for certain services or classes of applicants? If so, which services or classes of applicants?
3. Similarly, should the Commission maintain an exception to mandatory electronic filing for emergency STA's, e.g., should the Commission retain a process for paper or telephonic filing in cases of national emergency? Should the Commission consider accepting STA's on alternative "New Media" such as iPhones, Blackberries, Androids or other electronic devices which may work in an emergency when other devices do not? Should this concept be extended to simple renewals and address changes?
4. Should electronic versions of authorizations be deemed official authorizations? If so, should that affect rules on maintaining records in station files, or posting authorizations?
5. Should correspondence and notifications, e.g., dismissal letters, construction and renewal reminder letters, and other courtesy notices generated through CLS, be provided electronically to the applicant or licensee/permittee and contact-of-record? If so, should the Commission provide an opt-out option, which would allow applicants to receive paper copies of correspondence and notifications through regular mail?
APPLICATION PROCESS
1. What functionalities would be most useful for entering information and other data into a CLS application, e.g., system pre-filling information already in the database; previewing an application before filling out all of the required data fields; allowing third-party access to "draft" applications?
2. What kinds of real-time processing, e.g., "error checks" where the system will notify the filer of errors as information is entered into the system; real-time filing; and real-time monitoring of applications and authorizations, should be incorporated into the system?
3. Should contact information in the Commission's Registration System (CORES) and CLS be integrated? If so, to what extent? Should contact information updated in CLS be automatically updated in CORES? Should contact information updated in CORES be automatically updated in CLS? Should the Commission assign a single FCC Registration Number ("FRN") to each entity doing business with the Commission, with the ability to create sub-accounts that could be associated with the single FRN?
4. Should the Commission consolidate application procedural rules for CLS, to the extent not limited by statute? Should there be statutory changes? If so, please provide examples of where rules could be consolidated. For example, each Bureau employs a different process before accepting applications for filing. Should that process be consolidated across all services in CLS, or should some Bureau processes be maintained?
5. Are there unique terms used in particular service(s) that have a meaning that would be lost if they are conformed to the terms used in other services: If so, please provide examples. Similarly, should terminology be made consistent for purposes of filing applications in CLS? For example, should the term "authorization" cover the terms "license" and "permit;" should there be a distinction between "cancel" and "terminate" and "expire;" should the terms "return," "surrender," and "tolling" be maintained as separate terms; should the terms "consented to" and "granted consent to," as well as "non-consummate" and "dismiss" be consolidated for purposes of transfers and assignments?
6. Are there procedures followed in processing applications for experimental authorizations, wireline service, broadcast, public safety, satellite or wireless service that might benefit from being conformed to those used in other services? In contrast, are there any unique procedures used in the processing of one type of application that should not be changed in the CLS?
ACCESS TO CLS DATA
1. How would the public use application and licensing data in CLS, e.g., to search for individual applications or licenses; to conduct more in-depth analyses regarding a larger set of applications or licenses with interactive tools; and to access raw data to use as needed on an individual basis, e.g., other market-based analyses?
2. How would the public use tower siting and tower registration data?
3. What types of data would the public need to access in CLS to support those types of uses?
4. How should data in CLS be made accessible, e.g., access to individual applications or authorizations through standard web pages; access to larger amounts of data in easily accessible formats such as spreadsheets; access to very large amounts of data in various formats?
5. What historical data, e.g., tracking a license from issuance to the present (much like a title search) should be made accessible in the system?
6. Are there concerns about conversion of data? How should the FCC approach improving the accuracy of current data? Are there concerns about methods for improving data accuracy?
7. What kinds of mapping capabilities should be considered? What would be useful and to which user communities would these capabilities be most useful?
Phased-in Implementation. The Commission will deploy CLS in phases over several years. What problems have occurred from the perspective of system users when the Commission has implemented new electronic licensing systems in the past, including the Consolidated Data Base System, the International Bureau Filing System, and the Universal Licensing System?
Exceptions. Are there any services or types of filings for which CLS should not be used?