FCC Reduces Database Bugs
by Naina N. Chernoff
WASHINGTON Engineers and attorneys who
use the FCC’s Consolidated Database System report marked
improvement in the software.
Members of the Association of Federal Communications
Consulting Engineers and the Federal Communications Bar Association
say they’ve seen progress in solving some of the problems
associated with the database and its electronic filing capability.
The groups believe CDBS will continue to improve.
"I believe that the FCC’s staff is
carefully considering our comments and suggestions, and implementing
changes as their resources allow," said Joe Davis, a partner
at Cavell, Mertz & Davis Inc., who also served as AFCCE president
until June 2001.
"Some progress has been made, and we are
doing what we can to prompt further needed improvement."
Since the database was launched in 1999, users
have criticized CDBS because of its inaccurate records, causing
a headache for the consulting engineers who use the database to
generate technical studies (RW, May 23). Other users have reported
difficulty in filing mandatory applications using CDBS.
One senior engineer in the commission’s
Audio Services Division said the division has been working hard
to address users’ concerns in the last few months. An ad-hoc
committee from AFCCE has been meeting with division representatives
once a month. A similar committee from FCBA has been meeting with
the division whenever problems arise as well.
Among the improvements on which the Audio Services
Division staff has been working is rewriting software to ensure
that attachments to electronically filed applications can be viewed;
instituting 15 to 20 data validity checks to guard against inaccurate
data from getting into the database; and checking whether current
records contain accurate information.
The FCC engineer said the division also refined
the way the system works. For example, FCC staffers now confirm
that attached sales agreements can be viewed before sending out
a public notice.
Through a series of validity checks, the division
has searched all AM and FM database records for inaccurate data
in a variety of fields including frequency, channel, service codes,
station class, status, height, coordinates and subsidiary coordinates.
The staff has also checked different types of
information contained in engineering records including tables
to make sure each table contains legitimate values. The division
is conducting spot checks on a day-to-day basis to check that
records are archived properly.
Normally, validation of each application catches
missing or mistyped information, the engineer said, but these
checks were established to make sure the information makes sense.
Making strides
One engineering consultant, who asked that his
name not be used, said the division is making great strides despite
a lack of resources.
"The errors are not showing up as often,"
he said. But the FCC still needs additional money and manpower,
he said, and without such resources, eliminating the errors will
take "a long time."
AFCCE’s Davis is pleased with the progress
of the ad-hoc committee.
"I think it has been very helpful for the
consultants to hear from FCC staff regarding the continued development
of the CDBS and electronic filing," he said. "In turn,
I believe our feedback and comments to the FCC staff have been
helpful in their efforts to make the system work better."
Davis said the committee discussed three issues
in particular with the division: electronically filed exhibits/attachments
that are missing despite successful uploading,; error checking
when data is electronically filed; and the validity of engineering
data that is contained in the database. The FCC said it has resolved
or is close to solving many of the problems associated with these
issues.
Due to the error checking ability of the software,
Davis said, there have been some "bugs" that prevented
CDBS from accepting an application due to missing data, even the
data is not required for a particular station. However, he said,
the division staff has been responsive to correcting the problem.
AFCCE President Charles Cooper, a partner with
duTreil, Lundin & Rackley Inc., said the meetings would continue
until the remaining issues are resolved. After the improvements
are complete, he said, CDBS would be a valuable tool for submitting
and reviewing FCC files for AFCCE members as well as others.
"As with any large project, there are complications
that have to be defined and solved," Cooper said. "However,
AFCCE firmly believes that CDBS eventually will be a ‘can’t
live without’ service from the commission’s Mass Media
Bureau."
Lawyers agree
FCBA committee members expressed a similar sentiment
about the support they’ve gotten from the division.
"From my vantage point, they’ve been
open and tried ways to remedy problems," said Dennis Corbett,
attorney at Levanthal, Senter and Lerman. "The FCC is not
running from the problem."
Corbett said the FCC has been responsive to
FCBA’s concern since it started to make electronic applications
mandatory last year. When the FCBA questioned the mandatory electronic
filing of Forms 301, 314 and 315, the FCC agreed to phase in the
electronic capability, he said.
More recently, FCBA members met with the division
to discuss the use of federal regulation numbers on applications,
which is a common piece of information asked for on mass media
and wireless forms. Corbett said there has been some confusion
over what is required on the different forms and the system is
not uniform for each FCC database.
That is one thing that might be solved in the
future when the FCC contracts one contractor to do all of the
work on its database ¾ a plan already in place for the next
fiscal year, said an FCC source. In order to limit any problems
to the various databases that might result from the plan, he said,
the commission is taking steps to ensure a smooth transition.
