Public Knowledge Says ULS Too Difficult to Use to Be Much Help
Searching the FCC’s Universal Licensing System (ULS) to mine carrier data is too cumbersome and takes too long, Public Knowledge said in a filing. Other industry officials told us Friday they have shared PK’s pain trying to use the ULS.
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"While searching the ... data to support policy positions in several spectrum proceedings, PK noticed how challenging it is to gather meaningful information on carriers’ spectrum licenses and affiliate control in order to understand the mobile wireless market,” PK said (http://xrl.us/bobds5). “In the wake of necessary improvements to mobile wireless policies and the upcoming incentive auctions, it is essential that the ULS is well-organized and transparent.” PK said its review of records to get a better picture of wireless carrier spectrum holdings took three months and 460 hours of staff time.
Meanwhile, some records appear to be missing or take extra work to locate, the group said. “For example, there was no information on T-Mobile’s ownership disclosures from 2005-2009,” PK said. “Surely T-Mobile must have applied for or altered a spectrum license at least once in five years. An ownership search by T-Mobile’s registration number revealed archived files that provided the information. It turns out that the downloadable Ownership Database does not include archived files.”
PK Staff Attorney John Bergmayer said in an interview Friday the group wanted to call attention to the problems the group had trying to compile data for the spectrum aggregation and other proceedings. “We're doing fundamental work on spectrum issues, we're trying to draw out some correlations,” Bergmayer said: “One thing that would be nice to be able to do is to be able to tease out more relationships, to find out for this market who has spectrum and who is doing what. It’s just harder than you would think to find this information, which is” supposedly public. PK wanted to make the point “we're trying to participate in this proceeding, but there are just a lot of challenges you come into when you try to get to the right answer,” he said.
The FCC has put a lot of emphasis on its spectrum dashboard, which contains some basic information on spectrum holdings. “The spectrum dashboard is a good start,” Bergmayer said. “That’s exactly the kind of tool that we're going to need. But it’s not quite enough. What we really want to be able to do is find out more granular information and then make sense of that granular information. That’s the problem.”
Other industry lawyers agreed with PK. “It may be that people who regularly employ the ULS get used to it, but as someone who does not frequently need to use the ULS, I must say that I find it extremely difficult to master,” said Andrew Schwartzman, a lawyer who represents public interest clients. “It is not just that it has a difficult interface, but also that the process of tracking a particular licensee is, indeed, very cumbersome."
"They have a point,” said a longtime wireless industry lawyer. “It’s never been easy to do this kind of research, and as PK found, it’s almost impossible when you go back beyond the past five years. The FCC’s spectrum dashboard and similar initiatives are much more transparent and easier to access on a forward-looking basis, but it’s still hard to do research on past ownership. ... Part of the problem is that companies are only required to provide certain information in their ownership reports, so that’s all that you'll find in the reports.”