Hints on Filing Comments with the FCC

The FCC is interested in any experiences, knowledge, or insights that outside parties may have to shed light on issues and questions raised in the rule making process. The public and industry have the opportunity to comment upon Petitions for Rule Makings, NOI's, NPRM's, Further NPRM's, Report and Orders, and others' comments on the aforementioned documents. It is a common misconception that one must be a lawyer to be able to file comments with the FCC, but all that is necessary is an interest in an issue and the ability to read and follow directions.

Prior to drafting comments, it is crucial to read and understand fully the item you wish to comment on. Usually, the NPRM, NOI, or other item will specify and invite comment upon the issue(s) that the Commission is interested in studying further. Examination of the issue(s) and relevant documents is the most important part of the comment process. Comments may take any form, but below are some hints to assist you in writing them.

Format: There is no required format for informal comments, although if you plan to file formally, it is required that they be typed, double-spaced, and on 8.5" x 11" paper. Additional requirements for formal filings are set forth in Sections 1.49 and 1.419 of the FCC Rules. The Docket Number or Rule Making Number of the item at hand should be included on your comments, and can be found on the front page of the Commission document or public notice. You should also include your name and complete mailing address.

Content: Your comments should state who you are and what your specific interest is. (You do not need to represent yourself in an official capacity. You may, for example, express your opinion as a concerned consumer, concerned parent, etc. and sign your name.) State your position and the facts directly, as thoroughly but as briefly as possible. Explain your position as it relates to your experience and be explicit. Make clear if the details of a proposed rule or only one of several provisions of the rule are objectionable. If the rule would be acceptable with certain safeguards, explain them and why they are necessary.

Support: Statements of agreement or dissent in comments should be supported to the best extent possible by factual (studies, statistics, etc.), logical, and/or legal information. Support should illustrate why your position is in the public interest. The more support made, the more persuasive the comments will be.

Length: Comments may be any length, although it is preferred that they be succinct and direct. If formal comments are longer than ten pages, it is required that they include a summary sheet.

Time Frame: Your comments should be submitted well within the time frame designated on the original document or public notice. It is almost always included on the first page of an NPRM or NOI. However if the deadline has passed, you can still submit your views informally in a permissible ex parte presentation.

Filing: Send your written comments to Secretary, Federal Communications Commission, 1919 M Street, N.W., Washington, D.C. 20554. If you wish your comments to be received as an informal filing, submit the original and one copy. If you want your comments to be received as a formal filing, you should submit an original and four copies. For more specific filing information, please refer to the FCC Public Notice "Guidelines for Uniform Filings" available from the same address.

Reply Comments: As the name implies, reply comments are used to respond to comments filed by other parties. You may file reply comments even if you did not submit comments initially. When drafting reply comments, use the same guidelines expressed above regarding content and be careful not to raise additional or irrelevant issues.

Tracking your Comments: After you have properly filed your comments with the FCC, they will be part of the official Commission record. To track the progress of proceedings in which you have filed comments, you may check the Daily Digest or Federal Register for releases and notices. The Daily Digest can be obtained from the Office of Public Affairs, 1919 M Street N.W., Washington, D.C. 20554 or from a daily recorded listing of texts and releases at (202) 418-2222.

For Further Information: For further information, you may directly contact the Secretary's office at the FCC, (202) 418-0300. Explicit information about filings in rule making proceedings can be found in Sections 1.49 and 1.419 of the FCC Rules. Copies of any FCC documents can be obtained through the FCC's duplicating contractor, ITS, 1919 M Street N.W., Room 246, Washington, D.C. 20554, (202) 857-3800 or from one of the private distributors of FCC releases. A list of distributors is available from the Public Service Division, 1919 M Street N.W., Room 254, Washington, D.C. 20554, (202) 418-0190.

back