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Engineers Bemoan FCC Database

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.

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.
Electronic Filing Troubles Some UsersWhile 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
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

The phone number for the CDBS Help desk is (202) 418-2MMB (2662).