DRA states that limiting the duration of registration licenses to three years and requiring renewal of licenses will help detect and limit wrongdoing, and allows the Commission to eliminate inactive carriers from its database to improve the accuracy of the Commission's records. DRA asserts that, because existing NDIEC registration licenses have no expiration date, the Commission does not know which NDIEC registrants are currently providing service in California.
UCAN states that individuals and companies change over time, and limiting the duration of registration licenses will allow the Commission an opportunity to reconsider the qualifications of registrants subsequent to initial registration.
ExteNet opposes the OIR's proposal to limit the duration of registration licenses, and asserts this will impose administrative burdens on small NDIECs and the Commission.
As stated in D.97-06-107, our objective in establishing the simplified registration process is to allow applicants that have no history of questionable behavior and that present noncontroversial applications to rely on an expedited and inexpensive means of securing operating authority. To require registrants with no history of questionable behavior and noncontroversial applications to periodically renew their registration license undermines the objective of the simplified registration process and imposes on registrants a recurring obligation that is not borne by CPCN holders.
In response to Audit Report comments that it takes years for the Commission to investigate and penalize wrongdoing committed by registrants, the OIR proposed that requiring periodic renewal of registration licenses would help to more timely detect and limit or prevent wrongdoing by registrants. However, even with periodic renewal of registration licenses, the Commission would still need to investigate and prosecute violators using the same time-consuming processes that the Audit Report notes take years to complete (e.g., issuing an Order to Show Cause, initiate an investigation, etc.).
Moreover, periodic renewal would require the Communications Division to process hundreds of renewal applications each year, and, as a result, would require renewal applications to be submitted approximately six months prior to expiration of existing licenses. The substantial lead-time required for renewal applications further undermines our objective of providing an expedited and inexpensive means of securing operating authority.
Although substantial Commission resources would be required to administer a license renewal process, it is not clear that a renewal process would be any more effective at detecting or limiting wrongdoing than other tools already available to the Commission (e.g., the complaint process).
Therefore, for the reasons discussed above, we will not adopt the OIR's proposal to require the renewal of a registration license every three years.