So, it’s the end of the year, a time to assess where we are with our advocacy efforts. We have been busy for sure, but busy hasn’t generated many results in 2023. Without providing too many details, we are awaiting FCC action in response to several EWA petitions that will promote spectrum efficiency while eliminating unnecessary, 30-plus year old administratively choking license protocols at 800 MHz and at 150-470 MHz. We are also eager to engage with the FCC, following execution of an MOU, to improve the reliability of the data that resides in the Commission’s Universal Licensing System. Maybe in the new year, but one can’t rely on hope.  

But I’m wondering if there are other influences at work here that are slowing decisions down at the FCC. For example, the FCC’s Office of General Counsel announced last month that the FCC “is posting plain-language summaries” of its proposed rule makings and public notices that have been and will be published in the Federal Register. I have no idea why Congress thought that this is necessary, but according to the FCC, the “summaries provide an interested ‘non-specialist’ with a brief overview of the FCC’s proposed rules to facilitate public engagement with the rulemaking, consistent with the Providing Accountability Through Transparency Act of 2023 (PATTA).” Let that settle in for a moment and contemplate the unintended consequences of this new requirement. Wouldn’t time be better spent on drafting Orders in lieu of plain-language summaries? 

Let me try my hand at a plain language summary. “Well over a year ago the National Wireless Communications Council filed a petition to allow land mobile licensees to protect TV stations based on the station’s digital contour. The petition makes perfect sense as no TV stations are operating analog systems anymore, so having to protect something that doesn’t exist in the real world is goofy.” That’s the plain-language essence of the NWCC’s petition in less than 100 words, the prescribed limit. Will non-specialists know the difference between analog and digital propagation characteristics?  Doubtful.