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The FCC plans to improve its electronic filing systems by combining them into a single consolidated licensing system (CLS). A roundtable panel of industry experts participated in a workshop in May to help the commission through that process. The panel addressed such issues as: industry- and user-specific electronic filing issues; data availability and searching; consistent terminology; functionality features; error checking; notifications; system deployment; and any exceptions.

The systems currently included in the review are: the antenna structure registration system (ASR); cable operations and licensing systems (COALS); consolidated database system (CDBS); experimental licensing system (ELS); international bureau filing system (IBFS); and universal licensing system (ULS). The General Menu Reports System (GENMEN) is also expected to be included in the CLS, as well as the Wireline Competition Bureau's manual filing system. Currently, these systems are maintained separately by the various bureaus but have common data points.

The CLS will streamline access to electronic filing and underlying data. Potential new features include a single sign-on, a CLS manager and consolidated commission forms. It is also expected to be a “green” system with improved application processing time.

The single sign-on (SS-O) design will provide access to all applications, licenses and authorizations associated with an FCC registration number. It will also enable access to a manager, which could display application- and authorization-related alerts. Additionally, the feature will provide courtesy reminders, notifications and alerts regarding all of a licensee's authorizations and applications.

The FCC envisions a consolidated commission form to streamline virtually all application processes. This would include a main form to collect information applicable to all license and application types, followed by subforms to collect bureau-specific information. This is an expansion of the approach currently used by the Wireless Bureau in its Form 601.

Implementing such an approach will be a complicated effort, including consolidation of many forms and adjustments of rules and procedures. Because of the massive amount of work involved, the FCC expects the implementation to occur gradually over the course of years, with new features added on as elements of the system are deployed. Implementation will occur in phases; CDBS is expected to be dealt with in the first phase.

The end of the CLS path would signify the end of paper filings. The FCC has already reduced the number of paper filings to a relative minimum, but the official end of paper will mark a significant milestone in the evolution of the commission's processes.

A CLS page has been established on the FCC's reboot page ( through which it is collecting ideas and questions from the public. Further, the FCC has established a docket (MD Docket 10-73) in which it intends to release a notice of proposed rulemaking inviting additional comment.

Regulatory fee proposal

The FCC has asked for comments on proposed 2010 annual regulatory fees. Fees for UHF digital stations will increase vis-à-vis 2009, when fees were based on a station's pretransition analog facilities. The increases range from $3325 for stations in markets 11-25, $400 for stations in markets 26-50, and $1050 to $25,300 for stations in markets 1-10. These changes could be modified based on the comments the FCC receives.

Harry C. Martin is a member of Fletcher, Heald and Hildreth, PLC.


  • All TV licensees who have not already done so must file their 2009 biennial ownership reports by July 8 using the FCC's new Form 323.
  • By July 12, all commercial TV and Class A TV stations must electronically file their children's programs reports (Forms 398). Also by July 12, a certification of compliance with commercial limits during children's programs must be placed in stations' public files. Material to substantiate compliance with restrictions on the display of website addresses during children's programming must also be placed in the file by July 12.
  • Noncommercial TV stations in California, North Carolina and South Carolina must file their biennial ownership reports by August 2.
  • August 2 is the deadline for TV stations in California to electronically file their broadcast EEO midterm reports (Form 397) with the FCC.
  • August 2 is the deadline for TV stations licensed in the following states to place their annual EEO reports in their public files: California, Illinois, North Carolina, South Carolina and Wisconsin.

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