The communications law firm of Fletcher, Heald & Hildreth has asked the Federal Communications Commission — again — to back off the agency's requirement for FCC registration numbers and social security numbers by all individual attributable interest holders who file the revised commercial broadcast ownership Form 323. The law firm made its first request on this topic a couple of weeks ago.

In its petition (PDF), FHH states "Rather than adopt this requirement through formal commission action after providing interested parties reasonable opportunity to comment, the commission has instead imposed the requirement by inserting it into a revision of the Form 323 which the commission itself has still not formally released to the public for filing."

FHH calls the requirement "overly invasive." The Minority Media and Telecommunications Council recently agreed. Though it supports revising the form to obtain more ethnic, race and gender information from broadcast owners, MMTC, too, recently called the requirement of FRNs and SSNs invasive as well.

FHH feels it's going to be difficult for the commission to implement the information requirement without taking a few steps backward and going through the rulemaking process again. Right now, the forms are due on Jan. 11, 2010; the FCC said recently it's testing the new forms.