FCC Electronic Filing Transition Finalized for ULS, ASR

On September 17, 2020, the Commission released a Report and Order finalizing the Commission’s transition to an electronic-only Universal Licensing System (“ULS”) and Antenna Structure Registration (“ASR”) system for managing applications for Wireless Radio Service licenses (WT Docket No. 19-212).  As a result of these changes we recommend you review your licenses and authorizations in these systems to ensure that a valid, current e-mail address is on file.  The Commission adopts changes in five main areas:


  • The Commission adopts electronic delivery of correspondence generated from these systems to applicants, licensees, and registrants in the Wireless Radio Services.
    • The Commission finds that e-correspondence is the most efficient way to transmit critical Commission communications.
    • All e-mail correspondence will include, in the body of the message, the applicant name(s),  FCC Registration Numbers, any applicable file numbers, a list of any applicable call signs, the subject of the communication, and the disposition of the action.
    • Users may list up to two e-mail addresses associated with their license or application to ensure that e-correspondence is received by the appropriate recipient.


  • The Commission removes the remaining exemptions to mandatory electronic filing in ULS and requires electronic filing in the ASR System.
    • The Wireless Telecommunications Bureau recently implemented a solution that allows all applications that ULS previously could not accept electronically (Special Temporary Authority (“STA”) applications in certain market-based services, sublease applications, and multistep transactions) to be submitted electronically.
    • All ASR applications, including those for new registrations, modifications to existing structures, notifications of construction, and ownership changes, must be filed electronically in the ASR system.
  • The Commission requires electronic filing of pleadings related to Wireless Radio Services licenses and applications in these systems.  The Commission also requires electronic service where service of such pleadings is required.
    • The new e-service rules specifically require all petitions, pleadings, and other documents associated with licensing matters in the Wireless Radio Services to be served electronically upon a party, its attorney, or other duly constituted agent to the e-mail address listed in ULS.  Given that all parties will be required to provide valid e-mail addresses, service by e-mail to such an address may be considered complete upon sending.  A party that has failed to provide a valid e-mail address may not object to the adequacy of service.
    • The Commission requires parties to submit petitions, complaints, and requests for environmental review of proposed wireless communications facilities electronically.  For those without Internet access, the Commission’s waiver process can provide relief from the requirement to electronically file such documents.


  • The Commission requires that all applicants, licensees, and registrants in the Wireless Radio Services include at least one valid e-mail address on the relevant FCC Forms.
    • The Commission finds that requiring an email address on applications is appropriate and is not unduly burdensome applicants and licensees.  The Commission may dismiss an application as defective if an email address is not included.
    • Applicants and licensees are required to update their email address within 30 days from when that information changes.
  • The Commission sets a transition deadline of six months for these changes to take effect and to allow the Bureaus to shift to electronic correspondence.
    • As of September 17, 2020, the Commission will no longer print and mail paper authorizations.  All notification preferences will automatically set or reset to receive electronic correspondence.


Please Contact Us if you have any questions.

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