Regulation and Deregulation of Telecommunications

Introduction
Telegraph and Telephone
Radio and Television
Cable Television
Computer Services
Satellites
Federal Communications Commission

Introduction

The regulation and eventual deregulation of the U.S. telecommunications industry has been influenced by both the technology and the political and economic environment. When the Consent Decree under which AT&T divested itself of its 22 local operating companies was announced in 1982, the industry had been regulated by various public agencies for more than a century and a quarter. For the majority of that time, things had been rather stable in spite of patent disputes and several antitrust actions. The Hush-a-Phone case in 1956 and the Carterphone decision in 1968 signaled an end to the communications monopoly of AT&T. This paper examines at the development and regulation of the telecommunications industry, beginning in 1837 with Samuel Morse's American telegraph. Although convergence is blurring the distinctions among the various technologies, I have attempted to categorize each technology independently. I also provide an overview of the primary regulatory agency, the Federal Communications Commission and its various bureaus and offices.

Telegraph and Telephone

In February of 1837, the U. S. House of Representatives passed a resolution requesting the Secretary of the Treasury to report to the House of Representatives "upon the propriety of establishing a system of telegraphs for the United States" (Woodbury, 1837). With this action, the U. S. House of Representatives first entered into the era of electronic communication. Among the respondents to the Secretary of the Treasury's letter was Samuel F. B. Morse who proposed a system using electricity. Morse also suggested that the American telegraph should be thought of as a public utility and worthy of the attention of government. A year later, Morse proposed that "the sole right of using the telegraph belong, in the first place, to the Government, who should grant, for a specified sum, or bonus, to any individual or company of individuals who may apply for it, and under such restrictions and regulations as the Government may think proper, the right to lay down a way of communication between any two points, for the purpose of transmitting intelligence; and thus would be promoted a general competition." It was five years before Congress approved funding for an experimental line between Washington and Baltimore and not until May 24, 1844, were the well known words "What Hath God Wrought" transmitted on Morse's telegraph.

In 1855, Congress granted the right-of-way for construction of a line from St. Louis, Missouri, to the Pacific Ocean and in 1860, Congress passed the Electric Telegraph to the Pacific Act which called for bids to construct a government telegraph to connect the city of San Francisco to cities in the Atlantic, Southern, and Western states. The 1860 act called for the line to "be open to the use of all citizens of the United States during the term of the said contract, on payment of the regular charges for transmission of dispatches." (Congress, 1860)

The telephone grew out of the experimental work, in 1875, of Alexander Graham Bell on what was called the harmonic telegraph. The word telephone was not used until 1876 when the "Bell Telephone Company, Gardiner G. Hubbard Trustee," later to become simply the Bell Telephone Company, was formed. The company did not sell its telephones, but rather leased them. In the long run, this turned out to be a good idea; but in the short term, it created a shortage of capital. To overcome this problem, investors, in 1878, interested in the telephone's development in New England helped form the New England Telephone Company. Western Union also managed to get into the telephone business but after a series of patent disputes, Western Union agreed to stay out of the telephone business and Bell agreed to stay out of the telegraph business. Meanwhile, the National Bell Telephone Company had been developing a system of telephone exchanges that could be connected to allow for long distance calling. This Long Lines division eventually became a full-fledged subsidiary called the American Telephone and Telegraph Company (AT&T), and later became the parent company.

Telephone companies developed as locally run enterprises in the different states. Because they were usually local exchanges, they did not fall under federal jurisdiction. Hundreds of small telephone companies sprang up in spite of the patent rights of Bell. When the U. S. Supreme Court upheld the patent rights, many of the smaller local companies became part of AT&T.

In 1893, the original patents expired, opening the way for dramatic growth of independent telephone companies. The challenge of regulating telephone companies was viewed as one of rate structure: How the interface between long-distance carriers and local exchanges would be handled and who should bear what costs?

The larger AT&T competitors felt that Bell's restricted access contracts with local independents kept them out of the long-distance market. Woodrow Wilson's administration brought an atmosphere favorable to antitrust action against AT&T. The end result was the Kingsbury compromise of 1913 in which AT&T committed itself to disposing of its holdings in Western Union, discontinuing the acquisition of telephone companies that competed with Bell; and arranging for interconnections with independent telephone companies for toll long-distance calling. Meanwhile, in 1881, AT&T had acquired Western Electric Manufacturing Company. It eventually became Western Electric and was the manufacturing and supply arm of AT&T. In 1924, AT&T also developed a research arm, another wholly-owned company, Bell Labs.

The term common carrier dates back to the early days of transportation and the people and companies engaged in carrying goods from one location to another. One of the legal characteristics of a common carrier is that the carrier cannot refuse service to anyone if they are able to pay the required fee or fare. A 1910 federal law placed telegraph and telephone communication under common carrier status. (Congress, 1910) The act also established categories of service and a requirement of reasonable charges. The Federal Communications Commission was created by the Communications Act of 1934. This major piece of legislation and it's amendments control nearly all of the electronic media in the United States. The FCC's Common Carrier Bureau (CCB) regulates interstate wireline 'common carrier' services such as telephone and telegraph companies.

Although the Willis-Graham Act of 1921 recognized and legitimized AT&T's monopoly, the federal government, in 1949, filed antitrust proceedings against AT&T and Western Electric, asking that 1) the AT&T-Western Electric alliance be split up, 2) Western Electric divest 50 percent of its stock in Bell Labs, 3) the three companies license their patents to others on a nondiscriminatory basis, and 4) Bell operating companies buy all their equipment and supplies through competitive bidding. The defendants argued against divestiture saying that the current structure made it possible to provide equipment of advanced design and high quality at substantially lower prices than would be obtained without the current organization. They added that the ultimate beneficiaries of the unified structure were the users of the telephone service who thereby obtained better service at lower cost. The antitrust action was eventually settled in 1956 by a consent decree. The decree permitted AT&T to retain Western Electric but limited the Bell System companies to the telephone business.

Challenges to AT&T's telephone market monopoly continued. Three cases were important in this context. First, the Hush-A-Phone company wanted to attach a mechanical device to telephones to permit conversations to occur under noisy conditions. Although the FCC prohibited connection of the device, the court of appeals reversed the finding saying that the device was mechanical and not electrical and that the device could not harm the telephone equipment. Second was the case of Carterfone. With Carterfone, a voice-activated circuit switched on a radio transmitter when the caller spoke. When the caller stopped, the circuit was returned to the receive mode. Using the precedent of Hush-A-Phone, Carterfone showed that the device would not harm the telephone equipment.

A third case in the series of rulings which reduced AT&T's stranglehold on the market was Above 890. The common carriers argued that allowing private microwave systems to compete with common carriers would hinder the development of an efficient nationwide communications system. They also argued that the entry of private operators would result in increased rates for individuals and small businesses who would continue to use common carriers. They also argued for economic protection, stating that the FCC had a statutory obligation to protect the common carriers from a loss of business. In contrast, the private carriers argued that it should be a policy of the FCC to support freedom of choice for consumers. Eventually, the FCC ruled that frequencies above 890 kHz could be used for point-to-point communication by private carriers. Microwave Communications, Inc., currently known as MCI, was the first company to successfully take advantage of the FCC's more liberal policies. MCI applied to operate a private carrier service between Chicago and St. Louis. MCI later applied to provide direct-dial long-distance service and although the FCC ruled against MCI, the court of appeals eventually reversed the decision and AT&T was forced to offer interconnection service at negotiated rates.

A Justice Department antitrust suit filed in 1974 against AT&T, Western Electric, and Bell Labs was eventually settled in 1982 by a consent decree. The original decree was modified slightly by Judge Harold Greene before receiving final approval and has come to be knows as the Modified Final Judgment (MFJ). It resulted in AT&T keeping its long lines and long distance services, Western Electric, and Bell Labs. The 22 Bell operating companies were regrouped into seven regional holding companies (RBOCs). Gradual revision of the MFJ resulted in the RBOCs being permitted to enter nontelecommunication markets with few restrictions.

Regulation of common carriers is shared by both federal and state government. At the state level are public utility commissions--sometimes called public service commission, department of public utilities, public service board, corporation commission, and others. A continuing issue in this arena is the question of the commissions' independence. As an example, in states where the governor appoints the commissioners, the tendency may be to appoint those commissioners who will fulfill the governor's personal agenda. State legislatures can control commission activity and jurisdiction by passage of legislation and by budget appropriations. Although the FCC was historically concerned with regulating interstate telephone and states with regulating intrastate telephone, the distinction between the two have become fuzzy.

Radio and Television

The Commerce Department was granted the authority to regulate radio by the Radio Act of 1912. This act provided for government regulation of the maritime industry and was largely in response to the Titanic disaster. The act did not anticipate commercial radio broadcasting as it developed in the 1920s. Apparently hoping that the industry would work out its problems without government intervention, Commerce Secretary Herbert Hoover called a series of four radio conferences between 1922 and 1925. Only 22 broadcasters attended the 1922 conference but by 1925, more than 400 were present. Although Hoover stated, "I think this is probably the only industry of the United States that is unanimously in favor of having itself regulated," (Krasnow & Longley, 1978, p. 9) Hoover's efforts to regulate the industry were thwarted by a variety of court rulings. The Radio Act of 1927 was in response to the case of United States versus Zenith Radio Corporation, et al. In this 1926 case, Zenith Radio Corporation was granted a license to operate on a frequency of 930 kHz. Zenith did not like the idea that it had to share the frequency with several other stations and applied for an alternate frequency, 910 kHz. But, an agreement between the United States and Canada had limited 910 kHz to Canadian use and Zenith's application was denied. Zenith changed frequencies anyway. The Commerce Department took Zenith to court but a federal district court found that the Radio Act of 1912 did not give the Commerce Department the authority to establish radio regulations. Congress took action. The Radio Act of 1927 created a temporary five-member Federal Radio Commission (FRC). This act was eventually superseded by the Communications Act of 1934 which created the FCC as a permanent regulatory agency.

One feature of the Radio Act of 1927 was the controversial statement of "public interest, convenience, and necessity" as a standard for licensing radio stations. This phrase was borrowed from an 1887 Illinois railroad statute and was included in the Federal Transportation Act of 1920 (Le Duc, Don R., 1987, Beyond Broadcasting: Patterns in Policy and Law, New York: Longman, p. 10). It was also included in the Communications Act of 1934 and continues to be a source of controversy.

The Communications Act of 1934 sets the parameters within which the FCC functions. It defines the Commission, outlines the procedures to be followed and provides a "charge" for the FCC. In it's original form, Title II provided for regulation of Common Carriers (Telephone and Telegraph) and Title III provided for regulation of radio transmissions. Two of the better known sections of the act are Section 315 the equal time provision which applies to candidates for public office, and Section 326 which includes the no censorship clause.

Between 1934 and about 1975, the FCC created numerous regulations that affected broadcasters. Most of these were limited in their effectiveness but frequently resulted in a great deal of paperwork for the media.

The FCC began deregulating radio in 1981, first eliminating rules that required formal ascertainment of community needs. The commission also eliminated the requirement to keep program logs, guidelines for non-entertainment programming, and guidelines for the amount of commercial time. In general, the marketplace was allowed to "manage" most regulatory goals. The deregulation of television and noncommercial broadcasters followed in 1984. About the only areas of broadcast regulation remaining are the assignment of frequencies and the public interest responsibility requirements of the Communications Act. However, in 1990, Congress passed a bill that required television stations to serve the educational and informational needs of children and placed limits on the length and types of advertisements that could be shown during children's' programs.

Cross-ownership rules which were adopted by the FCC in 1970 and included in the Cable Communications Policy Act of 1984, prohibited a telephone company from providing video programming directly to subscribers in its telephone area. After cable was effectively deregulated under terms of the Cable Act subscriber rates rose rapidly and there were numerous complaints about service quality. The FCC rejected the idea of re-regulation as a remedy and favored competition instead.

In 1992, the Federal Communications Commission adopted rules that modified its cross-ownership rules and permitted local telephone companies to offer "video dialtone" services on a common carrier basis. The FCC also recommended to Congress that existing law be modified to permit the Local Exchange Carriers (LECs) greater freedom to compete with cable operators and other video suppliers by exercising control over programming. The hope was that competition from the LECs would encourage cable operators to reduce prices for video service and stimulate development of new services. Although the LECs generally agreed that video dial tone was a step in the right direction, they argued that its common carrier constraints would be an undue burden. Bell Atlantic states "If consumers are to reap the benefits of true competition, telephone companies must be permitted to compete in both the transport and creation of video programming" (Jessell, H. A., (1992, Feb. 10), "Video Dialtone Falls Short for Telcos," Broadcasting, p. 48-49).

Cable Television

Cable television systems were first developed in the late 1940s and early 1950s as community antenna television (CATV). Their initial role was to bring television broadcast signals to small and/or isolated communities where signals could not be picked up directly off the air. CATV used microwaves to carry the network signals to under-served areas. Cable was not seen as a threat to broadcasters because cable provided a larger audience at no cost to the broadcasters. The FCC routinely granted approval of the microwave relay systems. As the number of television stations grew, other services were developed as a means of attracting customers. When cable systems began to import television signals from distant cities in direct competition with local television stations, the FCC took notice and developed a series of regulations which were designed to prevent cable television from effectively competing with open air broadcasters.

The Cable Communications Policy Act of 1984 gave the FCC jurisdiction over cable television. Since a cable system does not use open air radio frequencies to transmit it's signal, it does not need a federal government license. However, it does need a franchise from the local government (usually a city or county government) whose right-of-way is used by the system's cable. Some states have enacted laws governing city and county franchise agreements.

Computer Services

The FCC began its "Computer Inquiry I" (CI-I) in 1966 to consider the implications of merging technologies in computers and telecommunications. The commissioners realized that it would be difficult to encourage the unregulated development of computer services while regulating the telephone system. The outcome, in 1971, of CI-I was an FCC ruling that the computer industry was not subject to its control. That same year, the FCC reversed an earlier decision and declared that, with only a few restrictions, anyone could enter the communication satellite business. The FCC's role in satellite communications is primarily related to coordinating frequency assignments with international organizations.

Computer Inquiry II was concluded in 1981 and resulted in a decision that stated that 1) computer companies could transmit data on an unregulated basis; 2) the Bell System was allowed to participate in the data processing market; 3) customer premise equipment and enhanced services would be deregulated and provided by fully separate subsidiaries of the carriers; and 4) basic communications services would remain regulated. Enhanced service provides for some processing of information being transmitted and is not regulated by the FCC. On the other hand, basic services provide no processing of information but only the transportation of information. These services are provided by the common carriers and are regulated by the FCC.

Computer Inquiry III resulted in a decision that the RBOCs and AT&T could offer unregulated, enhanced services if the companies agreed to an open network architecture (ONA). The order exempted independent telephone companies from this requirement.

Satellites

The issues surrounding regulation of satellite broadcasts are more complex than those related to the allocation of radio frequencies in the 1920s. Not only is there a requirement to allocate frequencies but also to determine positioning of satellites. The International Telecommunications Union works with other agencies to achieve an equitable regulatory environment.

AT&T launched Telstar in July 1962. This orbit of this satellite brought it into view about every 45 minutes and it was used to send television programs between the United States and Europe. But, it was hindered by the fact that it could not position itself at one point over the earth to maintain continuous communication. SYNCOMII, launched in 1963, was the first satellite placed in geostationary orbit.

Congress passed the Communications Satellite Act of 1962 which established the Communications Satellite Corporation (COMSAT). The corporation was given broad powers including planning, initiating, construction, ownership, management, and operation of satellite systems in cooperation with foreign countries. The FCC was charged with ensuring competition, granting construction permits and passing rules to carry out the provisions of the act. A portion of the act called for the development of a global satellite system. This resulted in the formation of the International Telecommunications Satellite Organization (INTELSAT).

The Commercial Space Launch Act of 1984 boosted private interest in satellite communication. It made it possible for private companies to launch and operate satellite systems. The FCC has imposed minimal regulatory restrictions on companies entering the satellite industry. The issues have related to coordinating frequency assignments and orbital positions with international organizations. Rates for satellite use are published in tariff schedules. The continued growth of satellite communication is likely to bring additional regulatory issues into the spotlight. Many of these will need to be resolved by international organizations.

Federal Communications Commission

There are four major sources of law which are relevant to the regulation of telecommunications in the United States: Constitutional law, statutory law, common law and administrative law (Smith, Meeske, & Wright, 1995, p. 2). The U. S. Constitution grants certain powers to Congress which writes statutes (laws) and delegates authority to administrative agencies, including the Federal Communications Commission (FCC). State constitutions grant similar powers to state legislatures and administrative agencies. The courts review legislative statues and the rulings of administrative agencies and determine whether they are within the scope of their authority, whether they are arbitrary or capricious, and whether they are constitutional. Most regulations affecting the electronic media are federal and state regulations that conflict with federal law are preempted.

The Federal Communications Commission is an independent federal regulatory agency responsible directly to Congress. Established by the Communications Act of l934, it is charged with regulating interstate and international communications by radio, television, wire, satellite, and cable. Its jurisdiction covers the 50 states and territories, the District of Columbia and U.S. possessions.

The FCC is directed by five Commissioners appointed by the President and confirmed by the Senate for 5-year terms (previously 7 years).

The President designates one of the Commissioners to serve as Chairman. As the chief executive officer of the Commission, the Chairman delegates management and administrative responsibility to the Managing Director. Certain other functions are delegated to staff units and bureaus and to committees of Commissioners. The Commissioners hold regular open and closed agenda meetings and special meetings. They also may act between meetings by "circulation", a procedure whereby a document is submitted to each Commissioner individually for consideration and official action.

When the Commission considers a change to telecommunications regulations, it issues a Notice of Proposed Rule Making (NPRM).

The FCC is made up of a number of bureaus and offices. These are briefly reviewed below with links to their respective pages.

Common Carrier Bureau

The Common Carrier Bureau (CCB) regulates interstate wireline 'common carrier' services such as telephone and telegraph companies. The objective of regulation is to provide customers with rapid, efficient, nationwide and worldwide services at reasonable rates. As technology and the marketplace change, competition now often fulfills this objective. Accordingly, CCB seeks to eliminate unnecessary burdens on carriers and consumers. The Bureau's Enforcement Division monitors and investigates complaints about common carriers.

Wireless Telecommunications Bureau

The Wireless Telecommunications Bureau (WTB) handles all FCC domestic wireless telecommunications programs and policies, except those involving satellite communications. Wireless communications services, includes cellular telephone, paging, personal communications services, public safety and other commercial and private radio services. WTB regulates wireless telecommunications providers and licensees. The Bureau also serves as the Commission's principal policy and administrative resource with regard to spectrum auctions.

The Wireless Telecommunications Bureau has seven divisions: Commercial Radio Division, Enforcement Division, Policy Division, Auctions Division, Private Radio Division, Licensing Division and Customer Services Division.

The Commercial Radio Division regulates Cellular Services, Personal Communications Services, paging, and Specialized Mobile Radio, Air-Ground, and Basic Exchange Telecommunications Radio Services.

The Enforcement Division ensures compliance with Commission rules, orders, and policies. The Division responds to public information inquiries concerning rates or practices and investigate EEO practices of wireless telecommunications providers.

The Policy Division develops rules and policies to govern wireless telecommunications services, based on current technical, economic, legislative, judicial and regulatory developments.

The Auctions Division conducts auctions of the electromagnetic spectrum. The Division works out the auction procedures, marketing, and application processing.

The Private Radio Division regulates matters concerning Public Safety, Industrial, Land Transportation and other private mobile radio services, Aviation, Marine, Amateur, IVDS, broadcast auxiliary service, Personal Radio Services, point-to-point microwave, antenna tower clearance, and the radio operator examination program.

The Licensing Division processes applications and licenses of Specialized Mobile Radio, paging, Private Land Mobile, private and common carrier microwave, broadcast auxiliary, amateur radio, IVDS, aviation and marine, and General Mobile Radio Services.

The Customer Services Division provides technical assistance to consumers, manufacturers, frequency coordinators, and others on questions related to application processing and licensing in the wireless telecommunications services.

Mass Media Bureau

The Mass Media Bureau (MMB) regulates the television and radio stations in the United States. The Bureau issues broadcast licenses specifing the community of license, the channel and operating power of the station. The conditions of the license ensure that the broadcast will be picked up without interference. If problems arise, the Bureau investigates and resolves the problems. MMB can fine a station or take its license if it finds that a broadcaster is violating FCC rules.

FCC rules generally do not govern the selection of programming that is broadcast. The main exceptions are that broadcasters may not broadcast obscene programming; they may broadcast indecent programming only when there is a strong probability that no children are in the audience; and they must limit the number of commercials aired during programming aimed at children. There are also rules to ensure that candidates for public office are able to have access to the air for their paid political ads.

Cable Services Bureau

The Cable Services Bureau (CSB) provides a single point-of-contact for cable related issues before the Commission. The Bureau implements the Cable Television Consumer Protection and Competition Act of 1992 by: promoting the availability to the public of cable television service; promoting competition in the cable marketplace; ensuring growth and development in the cable industry; and ensuring reasonable rates for consumers in areas that do not have competition to the cable system. The Cable Services Bureau is responsible for policy and rulemaking in cable television, as well as enforcement of the 1992 Cable Act.

International Bureau

The International Bureau was established in order to create an effective organization in which to centralize and consolidate the Commission's International policies and activities. Prior to the reorganization, international policy activities and other international functions were scattered across four Bureaus and two Offices throughout the Commission.

The International Bureau develops, recommends and administers policies, standards, procedures and programs for the regulation of international telecommunications facilities and services and the licensing of satellite facilities under its jurisdiction. The Bureau advises and recommends to the Commission, or acts for the Commission under delegated authority, in the development and administration of international telecommunications policies and programs. The International Bureau assumes the principal representational role for Commission activities in international organizations.

Office of Engineering and Technology

The Office of Engineering and Technology (OET) monitors scientific and technological developments and provides other FCC Bureaus and Offices with expert scientific and technical support and consultation. OET also tests equipment for compliance with FCC standards. OET coordinates the assignment of frequencies and adoption of standards with international committees and also coordinates the assignment of frequencies shared by the private sector and federal agencies.. Current issues before the board include Personal Communications Systems, High Definition Television, Digital Audio Radio Service, and others.

Compliance and Information Bureau

The Compliance and Information Bureau (CIB) is the Commission's primary point of contact with the public. Through its field office personnel, it carries out the enforcement, public service, and engineering programs of the agency. The Compliance Program ensures that U.S. radio laws and F.C.C. rules are observed. CIB inspects stations, resolves interference problems, monitors the radio spectrum to make sure that channels remain usable and free from interference, certifies radio-equipped ships to sail, and assists rescue agencies. The Bureau pursues administrative and criminal sanctions against parties that violate the laws and rules.

CIB also develops activities to inform assist, and educate licensees, user groups, industry groups, and the general public in all matters within the agency's purview. Field staff give presentations and answer questions in areas such as tower marking and lighting, operator services providers, modernization of the EBS, cable television signal leakage, AM directional stations, and consumer problems. CIB distributes forms for franchisees and complaints.

Other Offices

The Office of Managing Director (OMD) provides managerial leadership to, and exercises supervision and direction over, the FCC's bureaus and staff offices in management and administrative matters; formulates and administers all management and administrative policy programs and directives for the Commission; assists the Chairman in carrying out administrative responsibilities; advises the Chairman, Commissioners and management on administrative and related matters; and administers the FCC's management systems and directs agency efforts in improving management effectiveness, operational efficiency and employee productivity. Major organizational units within OMD include the Commission's Secretary which officially releases and receives documents; the Human Resources Management Division which handles personnnel matters; the Information Management Division which develops and maintains computer resources; and the Financial Management Division.

The Office of Plans and Policy (OPP), is the major economic and technical policy adviser to the Commission. OPP analyzes agenda items and develops long-term policy planning. Responsible directly to the Commission, OPP is supervised by the Chairman. OPP coordinates all policy research and development activities, both within the FCC and with other agencies.

The Office of Public Affairs (OPA), informs the press of the FCC's actions, extends public participation in the FCC's decision-making processes, and apprises the public of FCC policies in telecommunications. OPA issues daily news releases, public notices, copies of speeches and other informational material, prepares the Annual Report and other publications; handles written and walk in requests for information; and provides internal informational services.

The Office of Legislative Affairs (OLA) informs the Congress of the FCC's regulatory decisions, responds to congressional inquiries, and responds to proposed changes in existing law which affect the Commission or its processes.

The Office of Inspector General conducts and supervises audits and investigations relating to the programs and operations of the agency. The Inspector General recommends policies for activities designed to promote economy, efficiency and effectiveness, as well as to prevent and detect fraud and abuse in agency programs. The Inspector General also provides a means for keeping the Chairman, Commissioners and the Congress fully informed about problems and deficiencies at the agency.

The Administrative Law Judges preside over hearings and issue Initial Decisions. Generally, review of initial decisions is done by the FCC's Review Board. Its Decisions may be reviewed by the full Commission.

The Office of General Counsel advises the FCC on legal issues involved in establishing and implementing policy, handles legal questions affecting the agency's internal operations, coordinates the preparation of its legislative program and represents it in court. Through its Adjudication Division, the Office of General Counsel also assists the Commission in reviewing Review Board Decisions and, in specific cases, Initial Decisions of the Administrative Law Judges, as well as in drafting FCC decisions in adjudicatory cases.