Industry Supports All Electronic Filing for ULS, Other Systems

The few filings the FCC received on a September NPRM (see 1909060030) proposing that the agency fully transition its universal licensing system, its largest, from paper to electronic, were positive. Commenters said the FCC should do the same for other systems including for antenna structure registration. “The Commission’s recent efforts to modernize its filing and information retention systems have greatly improved public access to data, decreased costs for applicants and consumers, and improved efficiency for both the Commission and the companies it regulates,” Verizon said, saying more can be done. Applicants today can't file “two-step transactions, subleases, pre-close leases, and certain requests for special temporary authorization” in the ULS, the carrier said. “Lessees also cannot currently assign or transfer control leases in ULS,” Verizon said: “Instead, these applications must be filed on paper in Annapolis Junction [Maryland]. The office there then must forward the application to the appropriate FCC staff for processing. And the applicant must wait for a return package to ensure the application was filed.” AT&T urged the commission to “use this proceeding as an opportunity to consider other ways in which it can make its ULS and ASR systems more streamlined, transparent, and user-friendly. … AT&T believes the Commission’s rules for service of documents should be clear and consistent, and the Commission should proceed cautiously in changing these rules.” The Enterprise Wireless Alliance said electronic filing “should be the standard for all wireless application filings, authorizations, and correspondence.” Dealing with paper filings is time consuming, EWA said: “In EWA’s opinion, it is time for exempted classes of users to begin filing their applications electronically. The six-month period proposed in the NPRM should be ample to allow those parties to switch to a filing process that is used by many thousands of their peers.” The Blooston law firm group of rural wireless carriers noted that last year 5,000 of 425,000 ULS filings were manual and 15 of 7,000 ASR filings. “The Commission’s proposal is not unreasonable, provided that it is willing to liberally waive the electronic filing requirement in the event of electronic submission issues that occur from time to time,” Blooston said: “This is especially necessary for licensees in the Part 90 Private Radio Services, which were exempted from electronic filing when ULS was originally adopted.” Filings were posted last week in docket 19-212.