A CommLawBlog scoop: Agency brainstorming on possible "consolidated licensing system"
Word on the street (actually, word around the FCC) is that the Commission is embarking on a quest for what some might view as the bureaucratic equivalent of the Impossible Dream: an Uber-consolidated on-line licensing system to unify the balkanized collection of existing systems currently in use. This would mean “hello” to a new “Consolidated Licensing System” and “see ya” to the Universal Licensing System (ULS), OET’s Experimental Licensing System, the International Bureau’s “MyIBFS”, and the Media Bureau’s (apparently mis-named, or at least prematurely named) “Consolidated Database System” (CDBS). At this point, it’s not clear whether any other systems – such as the FCC’s tower registration operation – would also be included.
On-line filing – whether it’s used for license applications, routine reporting, or other requests or notifications – is obviously a Good Idea. It streamlines processes, permits easy on-line access to filed materials, facilitates cross-checking and searching, pushes the initial inputting burden onto the applicant (rather than the FCC’s staff), saves paper, and generally makes life better. Oh sure, there have been the occasional complaints about the user-friendliness of, say, ULS (née 1998) and CDBS (née 2000). And yes, some users have carped about how you can’t simultaneously search the various databases for information about a particular entity, or a particular location, etc.
But maybe, just maybe, the FCC has heard those cries of despair and frustration.
Recently the Commission convened the first of a series of brainstorming sessions – complete with “facilitator” and scribe – to begin the process of designing a new “Consolidated Licensing System” (CLS). Since this project (which as far as we know has not been formally announced) seems to be in the very early development stage, its contours are still a bit ill-defined, at least to us in the outside world. But having attended the initial brainstorming exercise, I can say that it looks like the Commission intends to do everything it can to Get It Right this time around: that is, the goal appears to be a full consolidated licensing database encompassing all spectrum users subject to the FCC’s authority, a system designed with maximum input from private sector users as well as the FCC's own staff.
The initial brainstorming session included representatives of Part 90 frequency coordinators – who routinely submit hundreds of applications into ULS every week – along with a boatload of FCC staffers. The latter made a considerable effort to solicit criticisms, praise and suggestions from the former. Word at the table was that similar meetings will be held in due time with other user constituency groups. Keep your ears, and your schedules, open.
So will we be seeing a spanking new and efficient CLS this year? Uhh . . . no. This is a vast, long-term project with a lot of moving parts (not to mention a cost likely measurable in the bazillions). From the tenor of comments at the first meeting, it appears that, in the best case scenario, we might start to see some initial elements of the CLS phased-in toward the end of 2010. Down here in the CommLawBlog.com bunker we are hopeful, but we won't be holding our breath.
As a practical matter, though, the longer the Commission takes to craft the CLS, the better off we all will probably be. With about a decade of experience with ULS and CDBS under our belts, we’re pretty much used to the various quirks of those systems, and the Commission has ironed out many more along the way. So we should be able to get by for a little longer with the status quo, particularly if the additional time is spent productively, honing the new CLS to maximize its user-friendliness as well as its bottomline bureaucratic utility.
While the Commission’s seeming reticence to go public with its plans thus far may suggest that the public is being kept away from the planners, my personal observation flatly contradicts that suggestion. Indeed, the staffers at the brainstorming session I attended were emphatic in their efforts to solicit maximum input from those of us in the private sector. The approach the Commission is taking is somewhat novel (at least for the Commission), so it makes sense for it to dip its toe in the water before jumping in all the way.
So be on the lookout for further opportunities to toss in your two cents’ worth, and be sure to have your thoughts ready when those opportunities arise. Informed and constructive suggestions from the public will be perhaps the most valuable contribution we can make to this project.