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RuralVision Central had ample opportunity to amend its applications by filing minor,  X- xcurative amendments prior to their return by the Commission.|f yO- xYԍ Subsequent to the filing of the Gates applications, but prior to their return, the Commission imposed a freeze,  {O`- xeffective April 9, 1992, on, among other things, the filing of most amendments to pending applications. Notice of  {O*- xProposed Rulemaking, 7 FCC Rcd 3266, 3270 n.35 (1992). Section 21.23(a) which allowed, under certain  xcircumstances, amendments as of right was also subsequently changed to include "provided , however, that . . . the  xYCommission has not otherwise forbidden the amendment of pending applications." 47 C.F.R. 21.23(a). However,  xRuralVision still had over three months, from January 2, 1992, to April 9, 1992, to amend its applications to include information, which should have been submitted with its applications.  Although Commission rules  xallowed certain applicants, as of right, to amend their applications prior to return or dismissal by  x the agency, such rules provided no opportunity for amendment after the applications were  X- xreturned. $ f {O- xԍ See, e.g., Edna Cornaggia, 8 FCC Rcd 5442, 5444 n.7 (Dom. Fac. Div. 1993) ("[I]t is no longer possible to  {Oc- xamend an application which has already been dismissed. . . ."); Earl V. Levels, 8 FCC Rcd 5506 (Dom. Fac. Div.  xK1993) (curative amendments filed with petition for reconsideration, attempting to supply a missing interference  yO -showing and other missing information, not allowed).  Therefore, petitioner is incorrect in stating that "the FCC has suddenly decided to prohibit applicants from filing, minor curative amendments."  X-   x15. Petitioner cites four instances where Commission staff sent deficiency letters to  xapplicants designated as tentative selectees following their participation in the random selection  Xi- xprocess, and allowed the tentative selectees to cure defects in their applications: Stephen  XT- x.Communications Inc., 8 FCC Rcd 355 (Dom. Fac. Div. 1993); T/V Communications Associates,  X?- x7 FCC Rcd 7647 (Dom. Fac. Div. 1992); Stephen C. Bailey, 7 FCC Rcd 7252 (Dom. Fac. Div."? ,-(-(ZZ{"  X- x]1992); and Microwave Video Services, 7 FCC Rcd 7254 (Dom. Fac. Div. 1992). Petitioner  xapparently seeks to equate its return notification letters with the deficiency letters sent to tentative  xselectees, and argues that the Commission's refusal to permit it to file curative amendments in  xresponse to its return notification letters is a violation of administrative due process. However,  xreturned applicants and tentative selectees are treated differently under Commission rules because  xreturned applicants have been found unacceptable for filing by Commission staff, while tentative  xselectees have been found acceptable for filing prior to participation in a lottery. "[A]ll  Xa- xapplications must be acceptable for filing in order to be included in a lottery." Second Report  xjand Order, Amendments of Parts 2, 21, 74 and 94 of the Commission's Rules and Regulations  x=in Regard to Frequency Allocation to the Instructional Television Fixed Service, Multipoint  X - xDistribution Service and the Private OperationalFixed Microwave Service, 57 RR 2d 943, 949  X - x(1985) (hereinafter MMDS Lottery Order). Since tentative selectees have already been found  xzacceptable for filing, only minor clarifications or additions should remain to be made to their  xapplications. Hence, Commission staff may send deficiency letters to a tentative selectee to cure  xminor problems prior to grant of an application that was otherwise acceptable for filing.  xxHowever, an application that has been adjudged unacceptable for filing is, by definition, defective  X-and properly returned or dismissed by Commission staff.    x16. The cited deficiency letters involved four applicants who filed their applications in  x1983, participated in the random selection process, had been selected as tentative selectees for  xqualification review and were subsequently notified by Commission staff of deficiencies in their  xapplications. The Commission staff provided an opportunity to cure such deficiencies by  X- xamendment within 30 days.'"f yO- xԍ At the time of petitioner's application filings, section 21.23(a)(2) provided a 14day period, after a lottery  xtentative selectee appeared on public notice, within which the applicant could make amendments to its application  xas a matter of right. In the cases cited, Commission staff provided the tentative selectees 30 days within which to  {O-cure deficiencies identified in the deficiency letters. See 47 C.F.R.  21.23(a)(3).' The deficiencies referred to in one of the letters appear to be  xdeficiencies which, under the rules applicable at the time the application was filed, did not render  xthe application unacceptable for filing. In the other three instances cited, the applications were  xMunacceptable for filing but were nevertheless entered in their respective lotteries. After the  xapplicants were chosen as tentative selectees, they were erroneously given an opportunity to  xzamend their applications to cure the deficiencies which made them unacceptable for filing in  X- x]contravention of the procedures established in the MMDS Lottery Order. However, the  Xo- x.Commission is not bound by such staff aberrational errors. See, e.g., North Texas Media, Inc.  XZ- xv. FCC, 778 F.2d 28, 33 (D.C. Cir. 1985) ("The initial improvident grant of a [shortspacing]  xwaiver . . . now described as an error, does not deprive the agency of authority to require future  X.- xyapplicants to meet certain standards in order to obtain such a waiver."); Quinnipiac College , 8  X- xFCC Rcd 6285, 6286 (1993); Walter P. Faber, Jr., 4 FCC Rcd 5492, 5493 (1989), recon. denied,  X- x 6 FCC Rcd 3601 (1991), aff'd mem., Faber v. FCC, 962 F.2d 1076 (D.C. Cir. 1992). Therefore,  xthe fact that three tentative selectees in the cited instances may have been improperly given the  xopportunity to cure deficiencies in applications, which should have been dismissed as  xlunacceptable for filing, does not compel the Commission to allow petitioner to amend its"!,-(-(ZZ "  xapplications after they were properly returned as unacceptable for filing, pursuant to established  X-Commission rules and procedures. f yOb- xԍ We note that none of the tentative selectees referred to by the petitioners received the MMDS station licenses sought in the subject applications since they failed to cure the stated deficiencies in a timely manner.   X-  !x17. Notice of Change in Commission Policy. Petitioner also states that the Commission  xfailed to provide prior notice of a purported change in Commission processing of MDS  xapplications which applied a new, strict standard by which RuralVision applications were  xdismissed due to minor defects. We note that RuralVision's applications were defective and  xunacceptable for filing in that petitioner submitted incomplete interference analyses. Pursuant to  xMsection 21.20(a)(1) an application is defined as unacceptable for filing if it is "defective with  xlrespect to . . . informational showings." 47 C.F.R.  21.20(a)(1). Interference analyses are  xkinformational showings, and Part 21 rules further state that "[a defective] application will be  X - xreturned to the applicant with a brief statement as to the omissions or discrepancies." Id.  X - x>Furthermore, as discussed in  812, supra, inadequate interference studies are not "minor defects."   x18. Petitioner further contends that "the FCC has dismissed RuralVision's applications  xwithout providing RuralVision with an opportunity to cure the one minor defect that its  xapplications contained . . . . [I]f the Commission wishes to prohibit MDS applicants from filing  xLminor, curative amendments, it must provide prior notice of this change in its MDS application  xprocessing policies." Applicants for new MDS stations on the H channels are required to file  xKspecific technical interference protection showings for cochannel stations with their applications.  xWhile petitioner seeks, on reconsideration, to add additional technical information to the  xinterference analyses submitted with its original applications, the Commission is under no  x\obligation to accept curative showings after an application has been returned or dismissed.  x<Indeed, there has been a series of cases denying attempts to submit such showings at that stage.  X- xSee note 15, supra. Thus, we conclude that petitioner may not amend its applications upon the  X-filing of a reconsideration petition, and its applications should not be reinstated nunc pro tunc.   @x19. Petitioner argues that the manner of the Commission's enforcement of its rules in  Xm- x-effect represents new application policies or standards which required full and explicit notice, but  XV- xthat RuralVision was not provided the requisite notice, citing Radio Athens, Inc., (WATH) v.  XA- x@FCC, 401 F.2d 398 (D.C. Cir. 1968). Petitioner adds, referring to McElroy Electronics  X,- xCorporation v. FCC, 990 F.2d 1351 (D.C. Cir. 1993), that the return actions evidence a lack of  xclarity in application standards. However, the Part 21 standard for acceptability of applications  X- xhas long been whether an application is "acceptable for filing." See 47 C.F.R.  21.31(b),  X- x[21.914. In referring to the Domestic Public Radio Services Order, f {O$- xԍ Amendment of Parts 1 and 21 of the Commission's Rules and Regulations Applicable to the Domestic Public  {O%-Radio Services (Other Than Maritime Mobile), 60 FCC 2d 549 (1976). it was explicitly stated that  x"all MDS applicants have been on notice since 1976 of the processing requirements for MDS  xapplications and the requirement that the applications be in a condition acceptable for filing' in"! |,-(-(ZZ "  X- x>order to be entitled to comparative consideration." New Channels, 57 RR 2d 1600, 1601 n.3  X- x{(1985).s\f {Od- xԍ Similarly, the interference study filing rule was adopted in a 1974 rulemaking order, see MDS Allocation  {O.- xOrder, 45 FCC 2d 616 (1974), and it is a longestablished policy that we need not allow minor, curative amendments  yO-after return of an application. s Moreover, in finding that inadequate demonstrations of interference protection  xconstituted defects rendering petitioner's applications unacceptable for filing, "the staff was  xengaged in the interpretation of an existing rule, and consequently, prior notice of the action was  X- xnot required." Id. Section 21.20(a) of the Commission's rules sets forth the two different tests  xjunder either of which an application is determined to be unacceptable for filing, and states that  xan application deemed unacceptable for filing will be returned to the applicant. 47 C.F.R.   Xc-21.20(a).   X5-  x20. The cited cases are also distinguishable on their facts. In Radio Athens, the  xapplication was reinstated in part because the duopoly ownership rule in question did not indicate  xthat an application with a duopoly problem would be dismissed without consideration. 401 F.2d  X - xat 403. In McElroy, the court concluded that a Commission order was vague at best and not  xreasonably understandable. In contrast, sections 21.20(a) and 21.914 clearly indicate the criteria  xZfor rendering an application unacceptable for filing and depriving it of comparative consideration;  X - xhence, petitioner's applications were returned accordingly. See Florida Cellular Mobile  X- xCommunications Corporation v. FCC, 28 F.3d 191, 198 (D.C. Cir. 1994) ("The Commission need  xnot supply a separate shopping list' specifying that each separate rule violation may lead to  xKdismissal. It is enough that the FCC rules are clearly spelled out and applicants are on notice that  XW- xtheir applications are subject to dismissal for failure to comply with these rules.").YWf {O- xԍ In Florida Cellular, the D.C. Circuit affirmed the Commission's dismissal of Florida Cellular's application  xbecause the regulations clearly provided that multiple ownership interests in competing applicants were prohibited,  xand Florida Cellular was on notice that its application was subject to dismissal for noncompliance with FCC  {ON-regulations. Id. at 193. The dismissal rule in question was  22.20(a)(1993), which is a verbatim restatement of  x- 21.20(a), except that  22.20(a)(2) calls for compliance with the Commission's rules and requirements while   {O- x21.20(a)(2) specifies substantial compliance. The Part 22 rules directly descended from rules in Part 21. See 73  {O- xFCC 2d 830 (1979); Domestic Public Fixed Radio Services and Public Mobile Radio Services, 44 Fed. Reg. 60532  x+ (1979). The court stated that "[t]he Commission's rules and orders put the applicants on notice that their applications  xKwould be subject to dismissal for failure to [substantially] comply with the FCC procedural and substantive rules."  {O-Florida Cellular, 28 F.3d at 198. Y Thus,  x=petitioner had full notice of the standard under which its applications were evaluated, and this  X)- xstandard is of sufficient clarity "to apprise an applicant of what is expected." See McElroy, 990 F.2d at 1358.  X-  x21. Petitioner further argues, citing Greater Boston, 444 F.2d at 852, that when an agency  xchanges its policy, it must articulate its reasons for doing so, but that the Commission has yet to  xarticulate the required "reasoned analysis" for its new policies. However, as discussed above, the  x<Part 21 acceptability standard is longestablished and the return of petitioner's applications is not  xat all indicative of a new policy or approach to evaluating applications. Furthermore, we find  xithat the return notification letters sent to petitioners gave sufficient explanation of the reasons for"u ,-(-(ZZ"  x/the return of the applications. Section 21.20(a), which governs the disposition of defective  xapplications, merely requires "a brief statement as to the omissions or discrepancies." In each  xcase, the return notification letters indicated at least one reason why the applications were  X- x\unacceptable for filing, and cited the relevant rule section or Commission decision. See  5,  X- xsupra. We have also   now further explained, in this order, the deficiencies which properly  xrendered petitioner's applications unacceptable for filing. Thus, the basis for the return actions  Xz-"may reasonably be discerned." See Greater Boston, 444 F.2d at 851.   Nx22. RuralVision failed to file adequate interference studies and, thus, its applications for  xGates, Tennessee were unacceptable for filing. Petitioner's applications were properly returned  x<by return notification letters. Despite petitioner's allegations, no new, strict standard was applied  xto its applications; rather, it was held to the Part 21 rules which applied to H channel applications  xand authorizations as of January 2, 1992. All MDS applicants are charged with being familiar  xwith Part 21 of the Commission's rules. Any applicant who "either ignores or fails to understand  xLclear and valid rules of the Commission respecting the requirements of an application assumes  X - xjthe risk that the application will not be acceptable for filing." Ranger v. FCC, 294 F.2d 240, 242  X-(D.C. Cir. 1961); see also Donald E. Benson, 8 FCC Rcd 1872, 1873 (Dom. Fac. Div. 1993). $V. CONCLUSION   x23. In view of all the foregoing considerations, we affirm the staff's return of the  x-applications under consideration in this order. Reconsideration is not justified and reinstatement of the applications is not warranted.   x24. Accordingly, IT IS ORDERED, that the joint reconsideration petition filed by RuralVision Central, Inc. IS HEREBY DENIED.   x25. IT IS FURTHER ORDERED, that the staff of the Video Services Division shall send copies of the decision to the authorized representative by certified mail, return receipt requested. pX` hp x (#%'0*,.8135@8: