Application Processing — Why the Delays?

We have been informed on more than one occasion that our FCC-certified frequency advisory committee (FAC) activities make EWA “an agent” of the FCC. It is a responsibility that EWA takes very seriously.  Our fundamental objectives are to assist the FCC by ensuring that license applications are complete, accurate and in compliance with Commission rules – and thereby also serve the interests of our customers. If the FCC believes the application needs to be modified, it bounces the application back to us with a request to amend it so that a license may be issued. The clear majority of FCC returns are not life-threatening and are easily resolved.  Even then, I am not a fan of “bounces” at all as they delay the entire process and there is nothing worse than touching a filing more than once.    

The number of application returns seeking statements from applicants to justify power requests, geographic coverage, spectrum capacity and at times simply ministerial information are increasing.  A significant percentage of these returns involve issues that EWA cannot fix without contacting the applicant leading to further delays.  If we knew in advance the warning signs of why applications might be returned or were informed of emphasis changes to the FCC’s review process, we would bring these requirements to the attention of our applicants at the front end and the number of returns would be reduced.  When we become aware of them after the fact, EWA is obligated to inform the applicant that amendments are necessary, attach justifications as appropriate and resubmit the application hoping upon hope that the amended application will pass muster.  I don’t understand why the licensing folks don’t communicate with us and other FACs in advance when they decide to change their review priorities or call us to avoid individual application returns.  We are not adversaries. Our efforts to put spectrum to efficient use quickly should be a collaborative effort.  

And then there are the IT traumas associated with keeping up with changes to the FCC’s Universal Licensing System (ULS). Most of you know that EWA and the FCC share licensing data daily so that the integrity of EWA’s automated frequency selection processes are not corrupted. Here’s the catch. There can be absolutely no variations in the number and content of data fields sent or received, otherwise the informational connection breaks down and applications cannot be filed with the FCC.  The system breaks roughly 10-12 times each year (!) requiring EWA to fund software upgrades.  Like application bounces, if we knew in advance that changes were to be made to the ULS, we could prepare so that there were no interruptions of service, but nay nay. For example, last week the process broke down as the FCC, for reasons unknown, added a new data field to the license application – “Whitespace YES or NO”. I am just thankful that EWA’s frequency coordination staff and IT folks willingly devoted time over this past weekend to make repairs and get applications back on track to accommodate this new one-character requirement.  

P.S.  We are still trying to find out who needs to answer this new and mysterious “Whitespace” question.  EWA hopes it isn’t our applicants since we would be hard-pressed to advise whether the answer should be YES or NO.