Friday, July 29, 2016

FCC Commissioner O'Rielly Publishes Blog Post on Mobility Fund Phase II and USF Reform

FCC Commissioner O’Rielly published a new blog post offering suggestions and elements for Mobility Fund Phase II and Universal Service Fund Reform.  Although he is skeptical of the timing and value of new mobile-only universal service subsidy program rules, he outlines six principles for reform that he suggests should be applied to any new program for wireless carriers.

His six principles for reform are as follows: 

  1. Prohibit overlap and target support – fund only those areas that do not already have wireless services of at least 4G capabilities; 
  2. Subsidize only one carrier – provide subsidies where competition cannot develop on its own and then only to one carrier;
  3. Phase out current support – design a very narrow phase-out of support for existing recipients of funds (suggests 2 years); 
  4. Populations, not roads – target population areas to use funds most efficiently;
  5. Providers must offer broadband – create requirements for subsidy recipients to offer broadband of certain capabilities for wireless carriers under a Mobility Fund Phase II;
  6. Finish RAF – address the Remote Areas Fund (RAF) in conjunction with creating the Mobility Fund Phase II.

Commissioner O’Rielly expresses his concern over creating a separate subsidy fund for wireless carriers, noting that users will eventually be able to use wired and wireless networks for all desired communications and subsidizing this would ignore improvements made in wireless broadband, voice capabilities, and 5G.  Secondly, he raises budgetary concerns and suggests the budget should be reevaluated in light of 4G LTE deployment because this funding will be needed in other areas.  He also suggests that the funding should be combined with all other unallocated high-cost funds and address open funding needs as a whole.

Please contact us if you have any questions.

Thursday, July 28, 2016

Upcoming Traffic & Revenue Filing Deadline

All common carriers that provided international telecommunications services in the calendar year 2015 must file a Traffic and Revenue Report with the Commission pursuant to Section 43.62(b)(2).  Traffic and Revenue Reports are due to the Commission on or before July 31 of each year.  This year, reports will be due August 1, 2016 (due to July 31 falling on a weekend).  In addition, any U.S. International Authorization Holder, regardless of whether it provided any International Telecommunications Service during the preceding calendar year, must file a Traffic and Revenue Report pursuant to Section 43.62(b)(1).  If needed, revisions are due October 31, 2016.

Data as of December 31, 2015 must be filed using the Section 43.62 Online Filing System.  Data must be entered directly into the forms in the online filing system except for Schedules 1 and 3, which must be downloaded using the following templates: Schedule 1 Template; Schedule 3 Template.  For more information on Traffic and Revenue reports, please see Filing Manual for Section 43.62 Annual Reports.  This manual provides the who, what, and how of the Section 43.62 reports. 

Common carriers must use Schedules 1 and 2 to report information for International Calling Service.  International Calling Service (“ICS”) is defined as International Message Telephone Service (“IMTS”) and International VoIP Service Connected to the Public Switched Telephone Network (“PTSN”), including International Call Completion Service for IMTS or International VoIP Service Connected to the PSTN.

Common carriers that billed less than $5 million in ICS Resale revenue and did not bill any Facilities ICS revenue for the reporting period are not required to report data for ICS Resale on their Traffic and Revenue Report.  But if a common carrier billed less than $5 million in ICS Resale revenue for the reporting period and also billed Facilities ICS revenue for the reporting period, then the provider is required to report data for ICS Resale as well as Facilities ICS.

A U.S. International Carrier that billed less than $5 million in revenue for an International Miscellaneous Service provided during the reporting period need not file data for that service on its Traffic and Revenue Report.  Each such carrier must, however, file data for any International Miscellaneous Service offering for which it billed $5 million or more in revenue for the reporting period.

Please contact us with any questions.

Public Notice Announcing Roll-Out Scheudle for New NORS Platform

The Public Safety and Homeland Security Bureau (“Bureau”) released a Public Notice announcing the roll-out schedule for the new version of the Network Outage Reporting System (“NORS”) platform.  The new platform contains improvements that will enhance the overall security and reliability of NORS, and has two interfaces: 1) a web-based interface and 2) an API/XML interface for companies that want to automatically file outage reports.  Providers of wireless, wireline, cable, satellite communications, and interconnected VoIP services must report significant disruptions or outages to their systems under Part 4 of the Commission’s rules.

The web-based interface will be opened on July 25, 2016. Companies not using the API/XML interface must use the web-based interface beginning at 3:00 PM on July 25, 2016.

The API/XML interface will be available on August 15, 2016.  Companies that plan to use this interface will be expected to file outage reports using the new version of NORS beginning on August 15th, and all NORS filings must be submitted using the new system after this date.

The new NORS production system can be accessed directly at  The Commission will transfer existing User IDs from the old NORS system to the new NORS production system by July 25th at 8:00 AM, but will not transfer any of the User IDs from the new NORS testing system to the production system.  If a user needs a new User ID, they can obtain one at

The new NORS testing system is currently available and open for testing through August 31, 2016.

Please contact us if you have any questions.

Wednesday, July 20, 2016

Public Notice Announcing Qualified Bidders in Forward Auction

The Wireless Telecommunications Bureau (“Bureau”) and the Incentive Auction Task Force (“Task Force”) released a Public Notice identifying 62 applicants that qualified to bid in the forward auction, and announced that bidding in the clock phase of the forward auction in the initial stage will begin on August 16, 2016.  The Public Notice includes details and dates regarding the forward auction and obligations for all applicants.

·         Qualified Bidders:  Attachment A to the Public Notice lists the names of qualified bidders and claimed bidding credit, if applicable. 

·         Non-Qualified Bidders:  Attachment B to the Public Notice lists each applicant that submitted an application but failed to qualify to bid in the auction.  All applicants, including non-qualified bidders, remain subject to the Commission’s rules prohibiting certain communications in connection with the auctions.

Please do not hesitate to contact us with any questions.

Monday, July 18, 2016

Public Notice Announcing Forward Auction User Guide

The Incentive Auction Task Force and Wireless Telecommunications Bureau (“Bureau”) released a Public Notice announcing the availability of the “FCC Incentive Auction Forward Auction Clock Phase Bidding System User Guide” (“User Guide”) (WT 12-269).  The User Guide describes the features of the bidding system that will be used to bid in the clock phase of the forward auction and gives detailed instructions for bidding and viewing the round results in the clock phase of the auction.

The User Guide is available online under the “Education” section of the Auction 1002 website at:

Please contact us with any questions. 

Friday, July 15, 2016

FCC Establishes Comment Dates for Proposed Part 4 Outage Rules

The Report and Order, FNPRM, and Order on Reconsideration regarding the new and proposed outage requirements were published in the Federal Register today, thus establishing the effective dates of many of the adopted rules and the comment dates for the proposed rules.

FNPRM:  The deadlines for comments on the proposed rules are as follows:
·         Comments are due August 26, 2016
·         Reply Comments are due September 12, 2016

Report and Order:  The adopted rules are effective August 11, 2016, except for those rules subject to OMB approval.  Please note that the compliance deadlines for particular rules may be pushed back several (i.e., 6, 9, 12) months from this date (see attached summary).  Please do not hesitate to contact us with any questions about these dates.   

The following provisions contain new or modified information collection requirements that have not yet been approved by OMB and therefore will not become effective in August:
  • Definitions of special offices and facilities and critical outage/airports under 47 CFR 4.5(b) and (c)
  • Definitions of OC3 metrics and interconnected VoIP clarifications under 4.7(d) and (e)(2);
  •  Adoption of (i) OC3 as a metric and (ii) a threshold of 667 OC3 user minutes under several provisions of 4.9.

The Commission will publish an additional document in the Federal Register announcing the effective date of the above provisions upon OMB approval.

Please contact us with any questions.