CDBS has been tweaked to accept pleadings relating to applications.
Dr. Seuss fans know that the Lorax speaks for the trees. And in that capacity, the Lorax is likely saying “thanks” to the Media Bureau. That’s because the Bureau has announced that it is now accepting application-related pleadings electronically, through the Commission’s Consolidated DataBase System (CDBS). So instead of filing mountains of paper (in multiple copies), petitioners can now save some trees by preparing a PDF of their pleading and, with a few relatively simple keystrokes, filing it with paperless online convenience.
The new filing option is available for pleadings directed to particular applications. Think informal objections, petitions to deny, petitions for reconsideration, applications for review . . . that sort of thing. Also, of course, pleadings that respond to any of those. (The new option does not apply to pleadings in docketed proceedings – those can be filed electronically, but through the Electronic Comment Filing System (ECFS).)
The Bureau’s public notice lays out the basic process:
- Log into your CDBS account;
- Get to the “additional non-form filings” screen;
- Select the option for “Informal Objection/Petition to Deny/Petition for Reconsideration/Application for Review/Opposition/Reply/Supplement”;
- Fill in the “pre-form” information (heads up – for this you’ll need the file number of the application to which your pleading is directed) and hit “enter”;
- Upload your pleading (PDF’s only); and
- Submit it.
CDBS should flash you its customary confirmation screen so that you’ll know that the pleading has been officially filed. (Helpful tip: it’s always a good idea, even if it’s not technically required, to retain a copy of that confirmation screen – by screen grab or screen print or whatever other means you may have – so that you’ll have some evidence of the filing, should any questions ever arise.)
If your pleading is directed to somebody else’s application, you’ll still have to serve that somebody else (or his/her counsel) with a hard copy of the pleading. But, importantly, the electronic filing will take care of your filing obligations as far as the Commission is concerned. No more original and X number of additional copies delivered to the Portals.
According to the Bureau’s notice, “[p]leadings filed electronically shall be treated as properly transmitted to the Commission as of the date of receipt.” That appears to say that you can file a pleading between the FCC’s normal quittin’ time and midnight, which should provide procrastinators an extra several hours in which to procrastinate.
(For the historical record we note that, according to sources within the Bureau, the first person to take advantage of the opportunity to file a pleading electronically through CDBS was none other than Fletcher, Heald’s own Peter Tannenwald.)