Engineers Bemoan FCC Database
by Naina Narayana
CDBS Users Describe a Raft of Ongoing Problems;
the Agency Says It Has Been Trying to Fix Them
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Electronic Filing
Troubles Some Users
While some engineers criticize the data-sharing
ability of the CDBS, electronic filing of the FCC’s
Mass Media Bureau’s forms has received mixed reviews
since users were required to file electronically last October.
"Making electronic filings with the
FCC has become a full-time job and requires detailed and
sophisticated knowledge, and in many respects, use of CDBS
is impenetrable to the public in general," said Charles
Naftalin, a partner at Holland and Knight LLP.
Naftalin said that, in his experience, the
FCC has provided little technical support to users who call
the CDBS help line.
"If a user calls a member of the Mass
Media Bureau directly with questions, most senior members
do not know how to use the CDBS online application system,"
he said. "They understand the commission’s mass
media rules and procedures fully, but not CDBS."
Jim Bradshaw, assistant division chief for
the FCC Audio Services Division, said the division has three
people handling calls. He believes many of the calls are
part of the natural learning curve associated with using
a new system. Users call the help line because they are
not sure about doing certain functions, he said; they are
not always reporting problems.
Also, much of the information needed by users
is contained in the online user’s guide, said Bradshaw.
He recommends users print it and keep it by their computers
for reference while submitting applications.
Other users, such as Jack Mullaney, president
of Mullaney Engineering, have had few problems with the
filing capability.
"In comparison with other databases
like the Universal Licensing System, (CDBS) is 100-percent
better so far," said Carl Gluck, vice president of
technical research at Salem Communications Corp., which
operates approximately 70 stations. "I’m impressed
with the CDBS system."
Gluck said the company, which has filed five
applications so far using CDBS, was accustomed to the paperless
format; it had been using the PDF format internally for
a year. He likes the way multiple users can view forms online
when filing multiple-party applications and the ability
to see whether applications have exhibits attached.
Gluck understands why some users have complaints.
"When change occurs, it’s hard to get used to,"
he said. "But once we get used to CDBS, it’ll
be better and quicker."
– Naina Narayana
|
WASHINGTON Engineers and attorneys who use
the FCC broadcast database say the system has major flaws, despite
efforts by the agency to improve the database.
Users of the Consolidated Database System cite
numerous inconsistencies and problems including what they describe
as lack of quality control, mislabeled or missing data, slow or
inadequate technical assistance and problems submitting online
applications.
One prominent consulting engineer called it the
poorest implementation of a database system that he’d ever
seen.
Stations are required to use the engineering database
to file 12 Mass Media Bureau applications electronically and verify
that proposed changes – such as upgrades, site changes and
power increases – do not conflict with new station proposals
from another facility. The CDBS was created in 1999 when the Mass
Media Bureau combined three separate databases.
Baby steps
FCC officials say they constantly are working to
improve the system.
"The system is not perfect," said Jim
Bradshaw, assistant division chief for the FCC audio services
division. "I know it has problems."
To speed things along, the division is analyzing
the system and ways in which its computer resources are being
used. Since CDBS was introduced in January 2000, Bradshaw said,
several improvements have been made.
Bradshaw and his staff are examining how to improve
response time for users doing queries or filing applications electronically.
In March, the division implemented a version of
CDBS for the FCC Web site in a flat-file format, the one used
for the earlier three databases. Bradshaw said the division created
this version for users who still have software compatible with
that format, in which users write routines to extract specific
information.
The new CDBS system, Bradshaw said, is a relational
format that accommodates different data types and allows more-efficient
data retrieval and storage.
Other improvements include a link that informs
users whether the system is down due to an upgrade, system error
or maintenance, and an online fee form allowing users to pay for
application fees using a credit card.
Since October 2000, the FCC has mandated electronic
filing of numerous applications – FCC Forms 301, 302-FM,
314, 315, 316, 318 and 347 – for AM and FM radio as well
as television stations, creating increased traffic on the CDBS.
The commission will not accept paper versions unless stations
submit a waiver request.
While many users, including engineering consultants
and attorneys, told RW that the CDBS would be useful in the long
term, they are infuriated by problems in obtaining data and filing
applications.
Major flaws?
Though the CDBS is more reliable than it was six
months ago, users said, some still dislike the way it works.
"It has been the poorest implementation of
a database system that I’ve ever seen," said Jack Mullaney,
president of Mullaney Engineering. "The FCC implemented CDBS
knowing it had major flaws. It borders on gross criminal negligence."
Mullaney, who uses the database for engineering
studies and filing applications, is far from impressed with the
way data was transferred from the old system to CDBS.
He said the information contained in CDBS about
several stations is wrong.
"You run the risk that you never know who
you’re supposed to be protecting because information in the
CDBS is incorrect."
Part of the problem, Mullaney said, is that the
outside contractor the FCC hired to do the job – Averstar
Group, owned by Titan Systems Corp. – was not sufficiently
familiar with the data.
But Averstar Program Director Warren Berger said
the real issue is that many engineers had to rewrite their analysis
programs when the CDBS was created in the relational database
format.
Still, Berger said, the Mass Media Bureau made
the decision to go with a relational database so users could save
time and employ standard database commands when analyzing the
information.
Berger acknowledged that bad data exists within
CDBS and said one way to help eliminate errors is for the public
to use the electronic filing system.
Users can avoid entering more inaccuracies into
CDBS because their forms must undergo two types of validation,
in which the system checks whether all fields have been filled
out correctly.
But in some areas of electronic filing, such as
sub-forms within a sale application in which multiple answers
to questions exist, a user can save incomplete or incorrect data
without validating it, Berger said.
"It is a consequence of the way the system
was initially developed," he said. "It allows the occasional
application in the door with bad data."
Though requiring validations in these sub-forms
would eliminate the problem, to fix the problem entirely in this
way would require a lot of work and time, Berger said. Averstar
is working on more pressing enhancements, he said.
He believes the user also has the responsibility
of making sure that applications are error-free as well.
Report errors
Bradshaw, too, said incorrect records exist. He
encourages users to report any errors and said appropriate changes
are made within days.
But Mullaney said he has found hundreds of errors
in records and said it would be difficult to e-mail the division
about the errors because of the overwhelming number.
"There are still many bad records in the database
that have yet to have been identified," said Doug Vernier,
president of V-Soft Communications, which creates broadcast propagation
software.
Some users have also found that a station is sometimes
dropped from the database because it has been mislabeled an archived
record instead of a current document.
In some instances, they said, new entries have
been entered incorrectly or lack necessary information such as
the two-letter state abbreviation, creating a problem for those
searching records by state.
In April, Bradshaw said the division created a
diagnostic program to flag some of these "bad" records,
allowing the division’s staff to research each record and
fix it. In the coming months, the division plans to expand the
program to search for several types of errors.
In terms of fixing all the records, according to
Bradshaw, there is no easy way to solve these problems.
"It’s virtually impossible to run a program
that corrects bad records," he said. "They need to be
researched individually."
Besides the diagnostic program, Bradshaw suggests
that users report errors so the division can fix the records.
To help eliminate problems the inaccurate records
can cause when doing engineering studies for their clients, both
Mullaney and Vernier have kept copies of the old FCC database
on their companies’ respective Web sites to use as comparative
records for the applications and facilities on file before December
1999, when the databases were combined.
"We suggested to all of our software clients
to run two studies, one with the old database and another with
the new CDBS database and look for discrepancies," Vernier
said. "This has avoided a complete mess."
But Bradshaw warns users to proceed carefully because
the data from the old database is now more than a year old.
"We have had people point to omissions or
faults with the new database in comparison to the old database,"
said Bradshaw. "Often times, they’re not right because
the station information changed."
The online user’s guide for the CDBS can
be found at http://svartifoss.fcc.gov:8080/prod/cdbs/forms/prod/cdbs_ug.htm
The phone number for the CDBS Help desk is
(202) 418-2MMB (2662).
