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. 



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.

Monday, July 31, 2017

FCC Releases Agenda for Aug. 3 Open Meeting

The FCC has released the following agenda for the "Rural Broadband Month" August 3 Open Meeting, scheduled to begin at 10:30 a.m.:

Connect America Fund Phase II Auction (Auction 903) -The Commission will consider a Public Notice to initiate the pre-auction process for the Connect America Fund Phase II auction which will award up to $198 million annually for 10 years to service providers that commit to offer voice and broadband services to fixed locations in unserved high-cost areas.  (AU Docket No. 17-182)  FCC FACT SHEET

Connect America Fund; Universal Service Reform - Mobility Fund -The Commission will consider an Order on Reconsideration and Second Report and Order that lays out a robust challenge process that will enable the Commission to direct Mobility Fund Phase II support to primarily rural areas that lack unsubsidized 4G Long Term Evolution (LTE) service.
(WC Docket No. 10-90; WT Docket No. 10-208)  FCC FACT SHEET

Modernizing the FCC Form 477 Data Program -
The Commission will consider a Further Notice of Proposed Rulemaking that takes a focused look at the Commission's Form 477 to improve the value of the data we continue to collect.
(WC Docket No. 11-10)  FCC FACT SHEET

Expanding Flexible Use in Mid-Band Spectrum Between 3.7 GHz and 24 GHz -The Commission will consider a Notice of Inquiry that explores opportunities for next generation services - particularly for wireless broadband - in the 3.7 GHz to 24 GHz spectrum range and asks about how we can increase efficient and effective use of this spectrum for the benefit of all services and users.  (GN Docket No. 17-183)  FCC FACT SHEET

Wireless License Renewal and Service Continuity Reform -The Commission will consider a Second Report and Order and Further Notice of Proposed Rulemaking that would adopt unified construction, renewal, and service continuity rules for the Wireless Radio Services, while seeking comment on a range of additional possible actions to increase the number of Americans with access to wireless communications services. 
(WTB Docket No. 10-112)  FCC FACT SHEET

Transmitter Identification Requirements for Satellite Digital Video Uplink Transmissions -The Commission will consider a Memorandum Opinion and Order that waives the requirement that satellite news trucks, and other temporary-fixed satellite earth stations transmitting digital video, comply with the Digital Video Broadcasting-Carrier Identification (DVB-CID) standard if the earth station uses a modulator that cannot meet the DVB-CID standard through a software upgrade.
(IB Docket No. 12-267)  FCC FACT SHEET

Designation Order -
The Commission will consider a Hearing Designation Order.

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 http://www.fcc.gov/live.

Please Contact Us if you have any questions, or require any further information.



Tuesday, July 18, 2017

Public Safety Bureau Reminder of Implementing Network Reliability Best Practices

The Federal Communications Commission's ("FCC's" or the "Commission's") Public Safety and Homeland Security Bureau (the "Bureau") released a Public Notice encouraging communications service providers to implement appropriate measures to prevent major service disruptions.

Based on submissions to the Commission's Network Outage Reporting System (NORS) and publicly available data, the Bureau has observed a number of major service outages caused by minor changes in network management systems.  These so-called "sunny day" outages do not result from a natural weather-related disaster or other unforeseeable catastrophe, and can result in "silent failures," which are outages that occur without providing explicit notification or alarm to the service provider.

After an analysis of the facts and circumstances surrounding 2014 outages, Bureau staff have determined that service providers likely could have prevented most of theses outages if they had implemented certain industry best practices.  In particular, seven best practices recommended by the Commission's Communications Security Reliability and Interoperability Council ("CSRIC") II, that could help prevent sunny day outages and silent failures:

  1. Awareness Training: “Network Operators, Service Providers and Equipment Suppliers should provide awareness training that stresses the severe impact of network failure, the risks of various levels of threatening conditions and the roles components play in the overall architecture.”
  2. Required Experience and Training: “Network Operators, Service Providers, and Equipment Suppliers should establish a minimum set of work experience and training courses which must be completed before personnel may be assigned to perform maintenance activities on production network elements, especially when new technology is introduced in the network.”
  3. Access Privileges: “Service Providers, Network Operators, and Equipment Suppliers should have policies on changes to and removal of access privileges upon staff member status changes.”
  4. Network Change Verification: “Network Operators should establish policies and processes for adding and configuring network elements that include approval for additions and changes to configuration tables.  Verification rules should minimize the possibility of receiving inappropriate messages.”
  5. Network Reconfiguration 911 Assessment: Service Providers and Network Operators when reconfiguring their network or Emergency Services Gateway should assess the impact on the routing of 911 calls.”
  6. Diversity Audits: “Network Operators and Public Safety should periodically audit the physical and logical diversity called for by network design of their network segment(s) and take appropriate measures as needed.”
  7. Network Monitoring: “Network Operators, Service Providers, and Public Safety should monitor their network to enable quick response to network issues.”
The Bureau encourages providers to review and consider voluntarily implementing these practices as appropriate.  The Notice also offers additional steps to help prevent future outages or mitigate the impact of outages, including implementing access control, validation and authentication procedures, software-based alarming, enhanced outage detection and examining automatic re-routing.

Please Contact Us if you have any questions.




Monday, July 17, 2017

Guidance on E911 Reporting Requirements

As expected, the Public Safety and Homeland Security Bureau (the "Bureau") has released a Public Notice providing additional guidance to Commercial Mobile Radio Service ("CMRS") providers regarding the upcoming deadlines for the E911 Indoor Location Accuracy Live Call Data Reports and Implementation Plan and Progress Reports.  Through this Notice, the Bureau provides a revised reporting template for CMRS providers to use in filing their periodic E911 location accuracy live 911 call data reports, which is due by August 1, 2017.  Non-nationwide CMRS providers must also file their location accuracy implementation plans and initial progress reports by August 3, 2017.

Live 911 Call Data Reporting Template:The revised template includes a minor change to the instruction for entering "yield" information in Section C of the template.  The revised instruction defines "yield" as "the percentage of total 911 calls that result in dispatchable location or x/y location information by morphology and position technology."  CMRS providers can access the revised reporting template (in Excel format) at https://www.fcc.gov/public-safety-and-homeland-security/policy-and-licensing-division/911-services/general/location-accuracy-indoor-benchmarks.  Providers are encouraged to use the revised reporting template for the next round of reports due on August 7, 2017.

Non-Nationwide Provider Implementation Plans and Progress Reports:The Bureau announced that non-nationwide providers may consolidate their implementation plan and progress reports into one filing.  Providers may file their implementation plan and progress reports using the Commission's Electronic Comment Filing System ("ECFS") and must reference PS Docket No. 07-114.

Please Contact Us with any questions.

499-Q Filing Deadline August 1

This is a reminder of the upcoming 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 August 1, 2017.  Carriers must provide revenue information for April 1 through June 30 and projections for October 1 through December 31.  Additionally, to the extent that interconnected VoIP and CMRS providers rely on a traffic study to report interstate revenues for the August 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 with any questions.

Tuesday, July 11, 2017

FCC Seeks Comment on BAC 3.7-4.2 GHz Petition for Rulemaking

The Consumer & Governmental Affairs Bureau Reference Information Center released a Public Notice seeking comment on a Petition for Rulemaking to Amend and Modernize Parts 25 and 101 of the Commission's Rules to Authorize and Facilitate the Deployment of Licensed Point-to-Multipoint Fixed Wireless Broadband Service in the 3700-4200 MHz Band (the "Petition").  Interested persons may file statements opposing or supporting this Petition within 30 days, or until August 7, 2017.

Please Contact Us with any questions.