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Rcd 12,253, 12,259 (1997). At the same time, the Commission   Xapproved a settlement among the remaining applicants and, pursuant thereto, granted the  X*application of intervenor Gonzales Broadcasting, Inc. See id. at 12,260.  LFCC rules provide that an application may be amended as of right before the application  Xq*  4is designated for hearing, see 47 C.F.R.  73.3522(a), and, in comparative broadcasting cases,   lwithin thirty days after the application has been designated for hearing if the amendment relates  XE*  to issues first raised in the designation order, see 47 C.F.R.  73.3522(b)(2). Thereafter, the   "agency will consider amendments "only upon a showing of good cause for late filing." 47 C.F.R.  X*   73.3522(b)(1). S X%*ԍ In Erwin O'Conner, the FCC Review Board identified the following factors as relevant to the good cause determination: "'0*0*0*'"ԌXX` ` that [the party seeking to amend] acted with due diligence; that the proposed amendment was not required by the voluntary act of the applicant; that no modification or addition of issues or parties would be necessitated; that the proposed amendment would not disrupt the orderly conduct of the hearing or necessitate additional hearing; that the other parties will not be unfairly prejudiced; and that the applicant will not gain a competitive advantage.x`  X *22 F.C.C.2d 140, 143 (1970); see also Royce Int'l Broad. Co. v. FCC, 820 F.2d 1332, 1335  X *(D.C. Cir. 1987) (citing Erwin O'Conner and discussing same factors in television licensing context). In an apparent effort to avoid the consequences of the "good cause"" 0*0*0*"   requirement, Jelks contends that his financial qualifications exhibit should have been allowed into   ^evidence without amendment of his application. Citing cases from 1981 and before, he asserts   "that Commission policy permitted applicants to tender financial qualifications evidence at variance   ^with their applications without submitting an amendment supported by good cause. Moreover,   he contends, even if there were a change in that policy prior to his hearing, the FCC provided insufficient notice of that change.  LtJelks is correct in noting that the FCC has not always been strict in requiring good cause   to amend, or amendment at all, in order to introduce evidence at variance with an application.  X1*  See Aspen FM, Inc., 6 F.C.C. Rcd 1602, 1603 (1991) (discussing pre1981 policy); Neil N.  X *  Levitt, 33 F.C.C. 720, 722 (Rev. Bd. 1962). The FCC has conceded as much. See Gonzales  X *  Broad., 12 F.C.C. Rcd at 12,259. Jelks is also correct that the Commission must provide notice   zof changes in application requirements, particularly where the sanction for failure to meet those  X *  requirements is dismissal without reaching the merits. See Salzer v. FCC, 778 F.2d 869, 875  X *  (D.C. Cir. 1985); see also CHM Broad. Ltd. Partnership v. FCC, 24 F.3d 1453, 145758 (D.C.   PCir. 1994). Jelks is wrong, however, in contending that the requirements at issue here had not   changed by the time of his evidentiary hearing and that the agency had not provided adequate notice of that change.  LPrior to 1981, the FCC required broadcast applicants to submit detailed documentation   demonstrating their financial qualifications. In 1981, the Commission substituted a revised   application form that, among other things, required only a simple "yes" or "no" certification to  X*  the financial qualifications statement set out above. See Mission Broad. Corp. v. FCC, 113 F.3d  X*  254, 258 (D.C. Cir. 1997); Revision of Application for Construction Permit for Commercial  X*  XBroadcast Station, 50 Rad. Reg. 2d (P & F) 381, 382, 397 (1981). Once it adopted this   certification policy, the FCC also "generally required that an applicant 'demonstrate that it had   a reasonable assurance of financing at the time that it made its initial certification' before it  X*  [would] be permitted to amend its application." Mission Broad., 113 F.3d at 261 (quoting  X*  bPontchartrain Broad. Co. v. FCC, 15 F.3d 183, 184 (D.C. Cir. 1994)). As we explained in  Xy*  Mission Broadcasting, the Commission "modified its liberal amendment policy ... when it   Beliminated the requirement that each applicant submit detailed financial documents; the agency   was concerned that an applicant would certify to its financial qualifications first and secure its"M 0*0*0* "  X*  ^financing only later." Id. (citing Pontchartrain Broad., 15 F.3d at 185); see also Aspen FM, 6 F.C.C. Rcd at 1603.  X*  X* L.The Commission's new policy was reflected in its 1985 decision in Chudy Broadcasting  X*  0Corp., 58 Rad. Reg. 2d (P & F) 133 (1985). There, the ALJ refused to permit a post-designation   0amendment, unsupported by good cause, of a broadcast application. On review, the Commission   rejected the applicant's contention that it should have been permitted to continue to prosecute its   "application without an amendment. And since without the amendment the applicant was left with  XN*  &a proposal that was not financially viable, the FCC upheld the dismissal of the application. See  X9*id. at 135. The Commission explained:   XX` ` We have recently undertaken to place greater emphasis on   providing service to the public in the most efficient, expeditious   manner possible. Temporizing with flawed proposals has in the  X *  past disserved the public interest by inordinately delaying the initiation of new service.x` X(#  X*  Id. at 13435 n.7. Cf. Hillebrand Broad., Inc., 1 F.C.C. Rcd 419, 419 (1986) (recognizing that   bprocedural deficiencies in applications did not always result in dismissal in the past, and that   l"applicants' temporizing activities have been indulged on occasion," but emphasizing that "times  X@*  "have changed and so has Commission policy"). See also Edwin A. Bernstein, 4 F.C.C. Rcd 8420  X+*  z(Rev. Bd. 1989), rev. denied, 5 F.C.C. Rcd 2843 (1990), aff'd sub nom. Lefebvre v. FCC, 926 F.2d 1215 (D.C. Cir. 1991) (table).  LNAs against these developments, Jelks principally cites two opinions which, he claims,   Fjustified his purported ignorance of the need to amend his application"a claim belied by his  X*  representation on that application that he would "file an amendment relating to his financial  X*  qualifications in the near future." The first is the FCC's 1983 decision in South Florida  X*  Broadcasting Co., which held that a pre1981 appli-cant that had failed to demonstrate its   .financial qualifications on the old form could not avoid a hearing simply by amending its  Xb*  application to add the post1981 "yes" certification. See 94 F.C.C.2d 452, 455 (1983); see also  XM*  Q Prime Inc., FCC 91M629 (ALJ Feb. 15, 1991). But the FCC's decision that an amendment  X8*  tis not sufficient to resolve a financial qualifications issue hardly establishes that it is not a  X#*necessary precondition to so doing.  LjJelks also cites a 1989 decision by the FCC's Video Services Division, holding that an   application was not necessarily "unacceptable for filing" simply because the applicant had marked  X!*  the "no" box regarding financial certification.  See Citylight Communications, Inc., 4 F.C.C. Rcd  X"*  41676, 167677 (1989). Although the Division did state in dictum that "[t]he remedy for failure   to certify is not dismissal, but amendment or, failing that, specification of a financial  X$*  qualifications issue against the relevant applicant," id. at 1677, the only question at issue was  Xq%*  4whether the application could be filed. Hence, Citylight simply did not address the question of   Phow an applicant who failed to amend could introduce evidence at a hearing to meet a financial  XE'*  Zissue designated against it. Of course, even if Citylight were inconsistent with the policy the FCC  X0(*  set for post-designation amendments in Chudy, Jelks could hardly take any comfort from it. As   counsel for Jelks conceded at oral argument, a subordinate body like the Division cannot alter")0*0*0*`'"  X*  za policy set by the Commission itself.  See Amor Family Broad. Group v. FCC, 918 F.2d 960, 962 (D.C. Cir. 1990).  LWe conclude that the FCC provided Jelks with adequate notice that if he wanted to submit   an exhibit at variance with his application, he would have to amend that application and show   good cause for late filing. Because he did not do so, the ALJ did not err in rejecting the exhibit,   and neither the ALJ nor the Commission erred in consequently denying Jelks' application. We   have considered Jelks' other arguments and find that none warrants reversal of the Commission's decision or further discussion here.