As part of our efforts to upgrade the FCC’s major IT systems, we’ve been working to modernize the Commission’s Electronic Comment Filing System (ECFS) to improve the public’s ability to engage with the Commission on important issues.
Public comments play an essential role in the Commission’s work. Our goal is to provide a more efficient and reliable way for the public to submit and access input on Commission activities. To reach that goal, we have spent months engaging with external stakeholders from law firms, industry and public interest groups, the press and FCC staff to solicit their feedback on the new system. Thanks to this essential feedback, we are nearing the final stages of the modernization effort and we expect to fully transition to the new system in late June 2016.
Then and Now
To understand the significance of this update, it helps to provide some context. Almost 19 years ago, the original ECFS was designed to provide a simple way to log on and submit a formal comment in an FCC proceeding, usually through a multi-page PDF attachment. In 1996, when ECFS was first created, it simply replicated the process of filing comments on paper. Over time, ECFS was modified to allow for other types of filings. Today, ECFS provides a public interface for several other purposes, including litigation of formal complaints, submission of petitions for rulemaking, submission of transfer-of-control applications, and other purposes that were not envisioned or supported by the original 1996 system.
The ways in which the public interacts with the Commission also have changed dramatically in the last two decades. For most of ECFS's lifetime, a typical proceeding received a small number of comments (ranging from 10 to 500), most filed by communications practitioners. In contrast, last year’s Open Internet proceeding received nearly 4 million comments from consumers and other interested parties. Today, the public expects to be able to easily submit comments in digital form and to have convenient access to all the other input received by the Commission, and the Commission needs a robust system capable of meeting the public’s expectations.
The current ECFS system was not designed to meet these demands. That’s why it must be brought into the 21st century. We have been diligently working on a modernized version of ECFS to reside on a commercial cloud platform so it can automatically adjust to handle periods of heavy usage. The new ECFS will have a public Application Programming Interface (API), so that outside groups have an easy way to submit and pull comments in bulk. It will also have the ability to read out loud the text contained in ECFS filings, making filings more easily accessible.
The Modernization Process
Updating ECFS involves much more than moving files from a legacy system to a new one. ECFS represents a set of detailed processes that have evolved over the 19 years that stakeholders of the Commission are accustomed to using. From the beginning, we realized that any new system needs to be familiar enough to enable regular users to utilize the new system without having to deal with a steep learning curve. At the same time, the new system needs to update and enhance outmoded processes that no longer meet users’ needs.
Over the last several months, the FCC has been testing a “beta” prototype of a modernized ECFS, as well as engaging with external and internal stakeholders to get input on how to improve the legacy ECFS system to meet today’s needs. These discussions helped us to understand which features should be continued in the new system and which should be improved or redesigned. We realize we may not have gotten everything exactly right. As we transition to the new system, we will continue to listen and incorporate user feedback.
We are also focused on ensuring all the older postings seamlessly enter the new system. We know it is important that the new system allows access to all of the files stored in the legacy system. In addition, an improved search function will better enable all interested parties to find the filings they’re looking for.
The New ECFS
The new cloud-based system provides the same features as the current ECFS, combined with some significant improvements:
- Improved usability: Improved layout and functionality based on stakeholder feedback, making it easier to file comments, check filing status, conduct research, and complete tasks faster.
- Greater reliability: Built on a commercial cloud platform, providing the ability to automatically adjust during periods of heavy usage.
- Streamlined process: Because we are no longer trying to replicate a paper-filing process, the new system is not designed to convert filings to PDF before they can be publicly viewed. Filings will be made available to the public in their native formats.
- Documented API: Providing outside groups the ability to submit and pull comments in bulk, with details on this API available here.
- Greater efficiency: More efficient model for the cost to maintain the new system, compared to a legacy “on premise” model.
- Increased accessibility: Ability to “read out loud” the text contained in ECFS filings, so that filings are more easily accessible to everyone.
On the final point, FCC takes web accessibility seriously and strives to set the standard for Government agencies. The new ECFS includes a combination of embedded tools providing the latest in web accessibility technology, including text-to-speech functionality, fonts for dyslexia and color blindness, and a beta voice navigation experience. Users can access these features by clicking on the accessibility icon featured on each page:
In the coming weeks, FCC staff will be conducting web-based tutorials of the new ECFS. The next tutorials are scheduled for June 7th and June 9th from 2:00-2:45 PM EST. To participate in a tutorial of the new ECFS, please email ECFSfeedback@fcc.gov. We strongly encourage everyone who uses ECFS to participate in one of these demos to become familiar with the new system and its features. We will formally announce the final switch-over date two weeks before the transition.
A sincere thanks to all the external and internal stakeholders who provided feedback during beta testing of the new ECFS. Thanks to your help, we believe the new ECFS platform will enhance all stakeholders’ ability to engage with the Commission.