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High Severity

Undefined Application Requirements Create Market Barriers

The Commission has unilateral authority to determine application forms, required documents, and fees without statutory guidance or transparency requirements. Applicants must demonstrate "proof of ability to provide the service" under subjective standards that lack objective criteria, creating unpredictability in licensing outcomes. Combined with Section 20's mandatory licensing requirement and criminal penalties for unlicensed operation, these undefined procedural requirements create significant barriers to market entry, particularly for small operators who lack resources to navigate regulatory uncertainty.