Manual “unlocking” of CDBS necessary to access Form 314 for some CP sales

So you’ve got this AM or FM construction permit, and you really don’t need it and you’ve found a willing buyer and you’ve cut your deal and now all you need to do is get the FCC to bless it. So what do you do? Head to CDBS, access your account, and fire up the old Form 314, right? Up comes the 314 pre-form asking for the file number of the authorization you’re trying to peddle. You type that in and suddenly (cue ominous music) – aughhhh! – an error message from CDBS Hell:

Invalid combination of Call Sign (NEW) and Facility Identifier (0)

Here’s the bad news: because of a glitch which we don’t fully comprehend, Form 314 is “locked” – and therefore inaccessible through the normal CDBS interface – when it comes to proposed assignments of AM or FM CP’s.  (It’s not clear whether the same is true of TV CP’s – if you have any information on that, let us know.)

But there’s good news.

The FCC is aware of the problem and is all over it like a cheap suit. If you need to file a 314 to assign a radio CP, here’s what you do:

Send an email to, explain what you want, and be sure to include the following information:

  1. Facility ID of the construction permit to be assigned
  2. The name of the permittee/assignor
  3. The relevant CDBS account number and password

The FCC’s staff will then manually “unlock” the form, making it available to you in your CDBS account. (Think of it as kind of like visiting your safety deposit box, only different.) You’ll be notified by email when the account has been “unlocked”. The process takes one-two business days. Bear that slight delay in mind if time is of the essence in connection with your sale (like, say, your CP is expiring and you’re fast approaching that narrow window available for selling it to an Eligible Entity in order to keep the permit alive for another 18 months).

It appears that this problem will be with us for another year or so, while the Commission’s crack contractors overhaul CDBS, paving the way for the “consolidated form” that may or may not make our lives better.

Of course, you might wonder why the FCC hasn’t issued a public notice alerting the universe of unsuspecting CP buyers and sellers about this departure from standard CDBS protocol. We’re not sure ourselves, but it certainly doesn’t seem right, especially since the job of notifying the public appears to have fallen to staffers who happen to be on the wrong end of the phone when one of those unsuspecting buyers or sellers calls in to ask about the error message. Keep your eyes out for a public notice – there’s bound to be one sooner or later.

One last tip: As you may have gleaned from the email address indicated above, the FCC staffer who bears the unfortunate brunt of this problem is none other than Konrad Herling, a true prince of a guy (and certainly one of the most pleasant, helpful and effective folks we’ve run into at the agency). But here’s the deal:   It’s best NOT to call Konrad about unlocking your CP Form 314’s; E-MAIL him, but do NOT call him. While he would doubtless be unfailingly pleasant with you on the phone, the fact is that, in the end, the conversation will not get you any closer to having the form unlocked for you; you’re still going to have to e-mail him the necessary information. So you can save both him and yourself some time by eschewing the phone and heading straight for your e-mail.