ODV,

A few things about the Commission’s email address requirement being discussed here.  It will become effective six months after publication in the Federal Register, so probably next June or Jul).  Experience with the pandemic certainly increased the FCC’s perceived need to go all electronic, but it has stated this to be its policy goal for more than 20 years.  The electronic FCC filing systems have continued to work well throughout the pandemic, keeping the Commission in business even though the offices are vacant.

• The email and electronic filing requirements are being implemented for all licensees that are not already subject to such requirements, which includes an FCC- estimated 2.25 million+ licensees that use the ULS licensing system. This change is not amateur-specific.
• In addition to moving correspondence to email, all amateur applications will have to be filed electronically (subject to seeking a waiver, see bullet point below).  When the ULS system was initiated in 1998, the Commission provided that a paper alternative could still be used if necessary. Overall, today the percentage of ULS paper applications has shrunk to fewer than 1 percent (2019 figure).  The amateur paper application load appears to be consistent with this figure, with 1,528 paper applications filed in 2018 and 1,339 in 2019.
• In general, the few remaining items that could still be submitted to the Commission on paper are being moved to electronic submission.    
• The Commission stated that it will routinely check returned email, as it currently checks returned postal mail, to correct errors and try a second time.
• According to the Commission, there will be provision for applicants to supply two email addresses.  This is analogous to the current ULS system procedures for licenses that use Form 601. (I am separately following up with the FCC staff to confirm that a second email address field will be available for amateurs to use, consistent with the Commission’s decision, because I tried and didn’t find one on my own amateur license record.  However, there are two email addresses for other types of ULS licenses that I hold or administer, and the email requirement for amateur applications is not yet in effect.)
• If an applicant is unable to file an application electronically, the Commission said that its waiver rules can be used to seek acceptance of a paper application pursuant to 47 C.F.R. 1.925(b)(3).  Among the explicit cognizable reasons for granting relief is that “the applicant has no reasonable alternative.”  This can be used to also address the email requirement if necessary.

I hope this adds some perspective to and information about the new electronic requirements. Let me know of any questions.

73, Dave K3ZJ

David R. Siddall

Managing Partner

DS Law, PLLC

1629 K St. NW, Ste 300

Washington, DC 20006

direct: +1 202 559 4690

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