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:

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.

FCC Releases Tentative Agenda for September Open Meeting

The FCC has released the following tentative 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 Nos. 17-105; 17-231) FCC FACT SHEET

Cable Television Technical and Operational Standards
– The Commission will consider a 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) 

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)

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. The NOI seeks comment on the capabilities of these systems to support direct calling to 911, routing to the appropriate 911 call center, and transmission of the caller’s location information, as well as to ensure that the 911 capabilities of these systems keep pace with technological developments and public expectations. (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.

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

Please Contact Us if you have any questions.

Monday, September 4, 2017

Wireless Microphone Order and NPRM Released

The Federal Communications Commission ("FCC" or the "Commission") released an Order on Reconsideration and Further Notice of Proposed Rulemaking addressing four petitions for reconsideration of the Wireless Microphones R&O concerning licensed wireless microphone operations in the TV bands, the 600 MHz "duplex gap," and several other frequency bands, as well as three petitions for reconsideration of the TV Bands Part 15 R&O concerning unlicensed wireless microphone operations in the TV bands, the 600 MHz guard bands and duplex gap, and the 600 MHz service band.  In the Order, the FCC makes technical revisions to the spurious emission limits that the Commission had adopted for licensed wireless microphone operations in several frequency bands and for unlicensed wireless microphone operations in the TV bands, and the 600 MHz guard band and duplex gap.  In addition, with respect to licensed wireless microphone operations in other frequency bands, the FCC adopts revisions to the channelization plan for licensed wireless microphone operations in the 169-172 MHz band.  Finally, the FCC terminates proceedings begun in 2008 and 2010 concerning various wireless microphone issues.

In the FNPRM, the FCC proposes to permit certain qualifying professional theaters, music, and performing arts organizations to obtain a Part 74 license that would allow them as licensees to obtain interference protections from white space devices in the TV bands and, when needed, also to operate in other spectrum bands available for licensed wireless microphone operations under Part 74.

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

Comments are due October 2, 2017.
Reply Comments are due October 16, 2017.

Please Contact Us if you have any questions.

Friday, August 18, 2017

TLP Attorneys Recognized by Best Lawyers®

Listed Logo for Telecommunications Law Professionals PLLC

Telecommunications Law Professionals is pleased to announce that three lawyers have been named to the 2018 Edition of Best Lawyers, the oldest and most respected peer-review publication in the legal profession.

Telecommunications Law Professionals would like to congratulate the following attorneys named to the 2018 Best Lawyers in America list:
Carl W. Northrop, Communications Law & Corporate Law
Michael Lazarus, Communications Law
Dennis P. Corbett, Communications Law

Best Lawyers has published its list for over three decades, earning the respect of the profession, the media, and the public as the most reliable, unbiased source of legal referrals.  It's first international list was published in 2006 and since then has grown to provide lists in over 65 countries.

"Best Lawyers is the most effective tool in identifying critical legal expertise," said CEO Steven Naifeh.  "Inclusion on this list shows that an attorney is respected by his or her peers for professional success."

Lawyers on the Best Lawyers in America list are divided by geographic region and practice areas.  They are reviewed by their peers on the basis of professional expertise, and undergo an authentication process to make sure they are in current practice and in good standing. 

Thursday, August 10, 2017

FY 2017 ITSP and CMRS Regulatory Fee Data Available

The FCC has released a Public Notice announcing that the FY 2017 Interstate Communications Service Providers (ITSP) and Commercial Mobile Radio Services (CMRS) data is now available for viewing in the FCC's Fee Filer.  The Public Notice provides instructions on logging into the Fee Filer to retrieve specific information.

Please Contact Us if you have any questions.

Monday, August 7, 2017

Wireless Resiliency Cooperative Framework Submissions

The Public Safety and Homeland Security Bureau (the "Bureau") has released a Public Notice inviting wireless providers that are interested in participating in the voluntary Wireless Resiliency Cooperative Framework ("Framework") to submit their intent in writing to PS Docket No. 11-60 within 30 days from the Notice (Sept 2).

As you may recall, the Framework, which was submitted by AT&T, CTIA, Sprint, T-Mobile, U.S. Cellular and Verizon set out a five-pronged approach for enhancing coordination during an emergency: (1) providing for reasonable roaming under disaster arrangements when technically feasible; (2) fostering mutual aid among wireless providers during emergencies; (3) enhancing municipal preparedness and restoration by convening with local government public safety representatives to develop best practices, and establishing a provider/PSAP contact database; (4) increasing consumer readiness and preparation through development and dissemination with consumer groups of a Consumer Readiness Checklist; and (5) improving public awareness and stakeholder communications on service and restoration status, through Commission posting of data on cell site outages on an aggregated, county-by-county basis in the relevant area through its Disaster Information Reporting Systems.

Please Contact Us if you have any questions.