Industry Support Continues on All-Electronic Filing for ULS, Other Systems
The FCC got general support for a September NPRM (see 1909060030) proposing the agency fully transition its universal licensing system (ULS), its largest, from paper to electronic. Initial comments in docket 19-212 welcomed the change (see 1911010064) and replies were…
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posted Thursday and Friday. American Tower said the FCC should act: “Electronic communications ease the administrative burden that accompanies traditional, non-electronic record keeping and allows for the creation of a more robust record for each transaction at a lower cost. Conducting business electronically is ubiquitous in almost every industry and government, making this move a win-win for the Commission and those it regulates.” AT&T supported a Verizon proposal that the commission permit nonstandard applications to be submitted electronically in PDF form or on a webform for receipt of nonconforming applications. “Currently, non-conforming applications, such as subleases and leasebacks, must be filed on paper in Annapolis Junction, and that office must then forward the application for processing,” AT&T commented: “Because filers of paper applications do not have the benefit of ULS controls that detect certain typographical errors and invalid entries, a ministerial error in an application may not be detected until it reaches Commission staff, and at that point filers often are required to start the process over again. This process is unpleasant and inefficient for applicants and Commission staff alike.” NTCA welcomed all-electronic filing for ULS and in the antenna structure registration (ASR) system. “Allowing additional types of applications to be filed via ULS or ASR would almost certainly benefit filers and the Commission alike through an ability to catch most application errors prior to submission and the ability of Commission staff responsible for reviewing the application to access the application online once the application is deemed complete,” NTCA said.