3 system to which concessions would have to conform. They explain, however, that under Article 210 of 1 LOTEL, in the case of concessions or licenses already granted the “lifetime” stipulated in Decree No. 1,577 would be honored. The petitioners state that as required under LOTEL, RCTV applied to have the terms of its concession transformed to conform to the requirements of the new system, and to that end filed an application with the Comisión Nacional de Telecomunicaciones (CONATEL) on June 5, 2002. They assert that CONATEL disregarded the transformation application and proceeded to enforce, in the case of RCTV, the new system of regulations and requirements instituted under LOTEL. The petitioners point out that had the provisions of LOTEL Article 210 been applied in conjunction with Article 3 of Decree 2 No. 1,577, RCTV’s concession would have come up for renewal on June 12, 2002, and would have been good for 20 years, and would expire on June 12, 2022. They observe that, on the other hand, had Decree No. 1,577, which predated LOTEL, been strictly observed, RCTV’s concession would have to be extended for another 20 years, starting on May 27, 2007, and would expire on May 27, 2027. The petitioners also argue, in the alternative, that assuming RCTV was not entitled to have its concession extended, the State was nonetheless required to pursue a transparent administrative procedure, governed by the rules of due process, to determine who the next station operator would be. The petitioners argue that in that process RCTV would be entitled to participate on a preferential basis or, at the very least, under the same conditions. 13. The petitioners maintain that as far back as 2003, independent television stations or channels in Venezuela faced the threat of losing the concessions or licenses they needed to operate. 1 Article 210 of LOTEL establishes: The National Telecommunications Commission shall, by a resolution, set up special schedules for transforming the concessions and licenses granted under the previous legislation, into the administrative authorizations, concessions or notification obligations or registrations established under this law. While that adjustment process is underway, all rights and obligations acquired under the previous legislation shall remain in full force, under the same terms and conditions established in the respective concessions and licenses. The transformation of the legal titles shall take place within two years following the publication of this law in the Official Gazette, shall be mandatory and shall be done in accordance with the following principles: 1) Transparency, good faith, equality and speed; 2) The rights given by concession to use and exploit legally granted frequencies shall remain fully in force. 3) This does not imply the granting of greater capacity to provide services to the public than that which the operators of telecommunications already enjoy, according to their respective legal titles. 4) The purpose, coverage and lifetime of the concessions or licenses in effect at the time the present law enters into force shall be respected. Subsequent renewals of the administrative authorizations or concessions provided for in this law shall be done according to the general rules contained herein. 5) The operators that currently have obligations with regard to standards of quality, development, expansion and maintenance of their networks, according to their respective licensing contracts, must comply with those obligations. 6) The only limitations that may be established are those that are compatible with the principles of this Law and the elaboration of those principles that the respective regulations may establish. 7) The transformation of legal title to which this article refers must be requested by the interested party within the time period established by the National Telecommunications Commission, which shall not be shorter than sixty (60) business days. Once the time period referred to in this section has expired, the National Telecommunications Commission will publish, in at least one newspaper with national circulation, a list of the concession holders that have not responded to the call to transform their titles, granting them an additional period of five (5) business days in which to do so, with the understanding that if such request is not made, it will be interpreted as a renouncement of the concessions or licenses that were obtained prior to the publication of this Law in the Official Gazette. The transformation of the current titles in no way means that telecommunications operators in existence prior to the date on which this law enters into force are to follow the general procedure for granting administrative authorizations or for cancellation, revocation or suspension of concessions or licenses under the previous legislation. 2 Article 3 of Decree No. 1,577 establishes: At the end of the concession, the parties in possession of the concession who, during the period specified in Article 1, have complied with the provisions of the Telecommunications Law, the Radio Communications Regulations and other legal provisions, shall be given preferential treatment if they are seeking an extension of the concession for another twenty (20) year period.