This past week, FCC Commissioner Michael O’Rielly asked whether certain information collection mandates by the FCC are “truly justified,” noting that certain rules stay in place past any useful purpose, while the burden can accumulate unnoticed for segments of the industry.  What an incredible observation and call for action, which has EWA’s total support. 

As a perfect “paperwork burden” example, EWA’s subsidiary Spectrum Equity, Inc. (SEI) holds several 220 MHz band manager licenses. In advance of March 1, every year, the FCC first takes the time and energy to release a Public Notice reminding band manager licensees of their requirement to inform the FCC of their current spectrum leases, and then, on March 1, a single page letter is submitted by SEI to a unique FCC web site address providing the information required. If you file one day late, it is necessary to file a “Request for Waiver – Late-Filed Band Manager Annual Report.” Unfortunately, we are intimately aware of this additional filing obligation. What a colossal waste of time and resources for both the FCC and the affected band managers since the FCC already retains the majority of the data. Is anyone reviewing the data at the FCC and for what purpose after fifteen years? Annual band manager reports are a habit whose time has come and gone!