Wednesday, November 1, 2017

Telecommunications Law Professionals Ranked in 2018 U.S. News - Best Lawyers® "Best Law Firms"

Telecommunications Law Professionals has been ranked in the 2018 U.S. News - Best Lawyers® "Best Law Firms" list nationally in one practice area and regionally in two practice areas.  Firms included in the 2018 "Best Law Firms” list are recognized for professional excellence with persistently impressive ratings from clients and peers. Achieving a tiered ranking signals a unique 
combination of quality law practice and breadth of legal expertise.

Telecommunications Law Professionals received the following rankings in the 2018 U.S. News – Best Lawyers "Best Law Firms":

  • National Tier 1
    • Communications Law
  • Metropolitan Tier 1
    • Washington DC
      • Communications Law
  • Metropolitan Tier 2
    • Washington DC
      • Corporate Law
The 2018 Edition of "Best Law Firms” includes rankings in 75 national practice areas and 122 metropolitan-based practice areas.  Ranked firms, presented in tiers, are listed on a national and/or metropolitan scale. Receiving a tier designation reflects the high level of respect a firm has earned among other leading lawyers and clients in the same communities and the same practice areas for their abilities, their professionalism and their integrity.
Feel free to contact us with any questions.

Wednesday, October 25, 2017

499-Q Filing Deadline November 1

November 1, 2017 is the deadline for filing the FCC Form 499-Q and supporting documentation:  All telecommunications carriers that provide interstate telecommunications services are required to file an FCC Form 499-Q Telecommunications Reporting Worksheet with the Commission on or before this date.  Carriers must provide revenue information for July 1 through September 30 and projections for January 1 through March 31.  Additionally, to the extent that interconnected VoIP and CMRS providers rely on a traffic study to report interstate revenues for the November 1 filing of the Form 499-Q, the traffic study relied upon must be included with this filing.

The Form and filing instructions may be found at https://usac.org/cont/tools/forms/default.aspx

Please Contact Us if you have any questions.




Monday, October 16, 2017

FCC Seeks Comment on New HAC Rules

The Commission released a Notice of Proposed Rulemaking (“NPRM”) on the Revisions to Reporting Requirements Governing Hearing Aid-Compatible Mobile Handsets, adopted at the September Open Meeting on Tuesday, September 26.  The NPRM seeks comment on revising the hearing aid compatibility reporting requirements for non-nationwide service providers to reduce regulatory burdens, and on whether the benefits of requiring an annual status report filing continues to outweigh the burdens of this information collection.

The NPRM seeks comment on the following proposals:

  • FCC Form 655 Exemption:  whether to exempt a service provider that is not a Tier 1 carrier ("Non-Tier 1 Service Provider") from the annual FCC Form 655 reporting requirements, and whether those requirements are still necessary to meet overall goals and deployment benchmarks.  For example, it seeks comment on the extent to which consumers rely on those reports, if consumers can obtain that information via third parties, and potential cost benefits of the proposed exemptions.  Additionally, the NPRM inquires into what materials and reports the Commission should rely on in helping to ensure Non-Tier 1 Service providers meet deployment benchmarks and other requirements, and to gauge the success of HAC models.
  • Alternative Size Standard:  whether the scope of any exemption should be based on an alternative definition of carrier and size standard.  A Non-Tier 1 Service Provider exemption would cover all non-nationwide providers, but under an alternative definition, it could instead be based on the number of subscribers.
  • Alternative Reporting Period or Certification:  alternative methods to reduce burdens associated with reporting requirements, if the Commission finds it is not in the public interest to eliminate the requirements completely.
  • Timing:  when a reporting exemption or modified reporting requirement would become effective if the Commission were to adopt such an approach, i.e., at a certain point in time, or once a provider has met a certain threshold.
  • Related Changes:  whether any changes to other aspects of the HAC requirements would be necessary or appropriate to accommodate or reflect a reporting exemption or modified requirement for Non-Tier 1 Service Providers.  For example, whether the FCC should retain the de minimis exception rule, and any other subsequent changes to Section 20.19 if the rules depend on variable factors.
  • Other Updates:  additional ways to streamline or update HAC reporting for all service providers, considering less costly ways to meet current and future deployment benchmarks, handset reporting, compliance tracking, and any other proposed changes with a cost benefit analysis of current and proposed collections.
The comment dates, pursuant to the Federal Register are as follows:

Comments are due November 13, 2017.
Reply Comments are due November 27, 2017.

Please
Contact Us if you have any questions.

Tuesday, October 10, 2017

FCC Releases 4G LTE Coverage Data Filing Instructions for MF-II


The Rural Broadband Auctions Task Force, Wireline Competition Bureau, and Wireless Telecommunications Bureau released a Public Notice with instructions for filing 4G Long Term Evolution ("LTE") coverage data pursuant to the MF-II Challenge Process Order.

As a reminder, the MF-II Challenge Process Order adopted parameters for a one time collection of 4G LTE coverage data, and instructed the Bureaus to provide filing instructions, including data specifications, formatting information, and other necessary technical parameters.  The Public Notice includes information on required filers and requested data, as well as submission instructions regarding clutter data, handset lists, certification and identification, and file uploading.

Additional information on the 4G LTE data collection can be found here.

Important Deadlines pursuant to FCC Public Notice :
  • Establish Contact:  By October 23, 2017, subject entities must submit contact information for this collection using a template that will be posted at http://www.fcc.gov/MF2-LTE-Collection.
  • Upload:  Data must be submitted by January 4, 2018

Please Contact Us if you have any questions. 









Friday, September 22, 2017

FCC Releases September Open Meeting Agenda

The FCC has released the following agenda for the September Open Meeting, scheduled for Tuesday, September 26, 2017, to begin at 10:30 am:

Amendment of Parts 74, 76 and 78 of the Commission's Rules Regarding Maintenance of Copies of FCC Rules - The Commission will consider a Notice of Proposed Rulemaking that proposes to eliminate rules requiring certain broadcast and cable entities to maintain paper copies of FCC rules.  (MB Docket No. 17-105; 17-231) 
FCC FACT SHEET

Cable Television Technical and Operational Standards -  The Commission will consider a Third Report and Order that modernizes its cable television technical rules to reflect the cable industry's use of digital transmission systems.  (MB Docket No. 12-217)  FCC FACT SHEET

Revitalization of the AM Radio Service - The Commission will consider a Third Report and Order that will relax or eliminate certain rules pertaining to AM broadcasters employing and maintaining directional antenna arrays.  (MB Docket No. 13-249)  FCC FACT SHEET

Updating Rules for Non-Geostationary Satellites in the Fixed-Satellite Service - The Commission will consider a Report and Order and Further Notice of Proposed Rulemaking that recommends updating and streamlining the Commission's rules to facilitate the licensing of the next generation of non-geostationary, fixed-satellite service systems.  (IB Docket No. 16-408)  FCC FACT SHEET

Revisions to Reporting Requirements Governing Hearing Aid-Compatible Mobile Handsets -

The Commission will consider a Notice of Proposed Rulemaking that seeks comment on revisions to the wireless hearing aid compatibility annual reporting requirement to provide relief to non-nationwide service providers.  (WT Docket No. 17-228)  FCC FACT SHEET

Toll Free Assignment Modernization - The Commission will consider a Notice of Proposed Rulemaking that proposes to amend the Commission's rules to allow for use of auctions to assign certain toll free numbers and considers other means by which to modernize the administration and assignment of toll free numbers. (WC Docket No. 17-192; CC Docket No. 95-155) 
FCC FACT SHEET

911 Access, Routing, and Location in Enterprise Communications Systems -  The Commission will consider a Notice of Inquiry that seeks comment on the provision of 911 by enterprise communications systems that serve businesses, hotels, educational institutions, and government entities.  (PS Docket No. 17-239)  FCC FACT SHEET

20th Mobile Wireless Competition Report - The Commission will consider a Report analyzing the state of competition in the mobile wireless industry.  (WT Docket No. 17-69)  FCC FACT SHEET


Enforcement Bureau Action - The Commission will consider an enforcement action.

Public Safety and Homeland Security Presentation -  The Commission will receive a briefing from the PSHSB on the Commission's response to recent hurricanes.

In addition to the links above, drafts of the above items will also be made available here.  Audio/Video Coverage of the meeting will be broadcast live with open captioning from the FCC Live web page at www.fcc.gov/live.

Please Contact Us if you have any questions.

















Monday, September 11, 2017

2017 Regulatory Fees Report and Order and FNPRM Released

The Commission released the Report and Order ("Report") and Further Notice of Proposed Rulemaking ("FNPRM") on the Assessment and Collection of Regulatory Fees for Fiscal Year ("FY") 2017.  The Report adopts a schedule of regulatory fees to access and collect $356,710,992 in fees for FY 2017.  The Commission also announced in a Public Notice that the Fee Filer is open for payments.  Payments must be received electronically by September 26, 2017.
The Report projects approximately $22.17 million from regulatees in the International Bureau, $88.69 million from Wireless Telecommunications Bureau ("WTB") regulatees, $115.58 from Wireline Competition Bureau ("WCB") regulatees, and $130.27 from Media Bureau regulatees.  Regulatory fees are "derived by determining the full-time equivalent number of employees performing" activities ("FTEs").

The Report also reallocates FTEs, specifically 38 FTEs in the WTB associated with the Universal Service Fund ("USF") now assigned to work on non-high cost programs of the USF as indirect and four FTEs that work on changes to numbering issues from the WCB to the WTB due to USF landscape changes.

The FNPRM seeks further comment on the appropriate tiers for calculating terrestrial and satellite international bearer circuit fees raised in previous NPRMs and the methodology for calculating cable television subscribers in multiple dwelling units.

For more information on reg fees, click here: http://www.fcc.gov/regfees

Please Contact Us if you have any questions.

WTB Seeks Comment on Process for Relicensing 700 MHz Spectrum in Unserved Areas

The Wireless Telecommunications Bureau has released a Public Notice in which it seeks comment on certain aspects of the process for relicensing 700 MHz spectrum in unserved areas.

Under the 700 MHz Second Report and Order, the FCC set forth rules governing wireless licenses in the 700 MHz Band that, among other things, established interim and end-of-term construction requirements.  Under the FCC's keep-what-you-serve rules, if a licensee fails to meet its end-of-term construction deadline, its authorization to operate will terminate automatically without FCC action for those geographic areas of its license authorization in which the licensee is not providing service on the date of the end-of-term deadline, and those areas will become available for reassignment by the FCC.  The FCC delegated to WTB the authority to establish by Public Notice the process by which licenses will become available for relicensing.

Licensees that fail to meet their end-of-term construction benchmark will be required to make additional keep-what-you-serve filings.  In the Public Notice, WTB proposes a process whereby the licensee would demonstrate their serve area in order to determine the area that they would keep – and the area that would be relicensed

WTB seeks comment on its proposed methodology for determining such service area (smooth enclosed dBuV/m field strength contour of existing facilities as of the end-of-term deadline, with a potential alternative approach), the process for applying to serve unserved areas available for relicensing, and the process for meeting buildout requirements once a licensee obtains any such unserved area.

The comment dates, pursuant to the Federal Register are as follows:

Comments are due September 27, 2017.
Reply Comments are due October 10, 2017.

Please Contact Us if you have any questions.