Friday, August 26, 2016

FCC Order on Reconsideration and FNRPM on Public Safety Narrowband Operations

The Commission published an Order on Reconsideration and Further Notice of Proposed Rulemaking (“FNPRM”) regarding the rules governing public safety narrowband operations in the 769-775/799-805 MHz bands.  In October 2014, the Commission released a Report and Order amending its Part 2 equipment rules to require that equipment manufacturers include a declaration of CAP compliance with any application for certification of equipment capable of operating on the 700 MHz interoperability channel.

The FNPRM seeks comment on the use of Vehicle Repeater Systems (VRS) on 700 MHz General Use and State License channels.  Additionally, it seeks comment on required radio features to meet CAP requirements for interoperability, and whether to adopt all, some or certain additional recommended sets and capabilities.  In the Order on Reconsideration, the Commission modifies certain proposals in response to requests and concerns filed by TIA, Motorola, APCO, and others.  As a result, it amends Section 90.548(c) of the rules to require either CAP compliance, or an equivalent demonstration of compliance with the standards and evidence of interoperability across vendors, before marketing or sale of that equipment.  The Commission clarifies that a state may either assume responsibility for air-ground channels itself or is permitted to delegate responsibility for approval.  It also makes several corrections and amendments to its rules in the Report and Order, specifically sections: 90.535; 90.523; 90.209; and 90.210.

Comments on the FNPRM are due 30 days after publication in the Federal Register.
Comments on the FNPRM are due 45 days after publication in the Federal Register.

Please contact us with any questions.

Monday, August 15, 2016

NRUF Form 502 is Due August 1, 2016

The Numbering Resource Utilization/Forecast Report (NRUF) Form 502 is due to be filed by August 1, 2016.  The North American Numbering Plan Administrator (NANPA) is required to collect, store and maintain number resource utilization and forecast data.  Accordingly, the FCC directs that NANPA number assignees holding geographic and/or certain non-geographic telephone numbers must report on their holdings twice each year (February 1 and August 1) using Form 502.  As with prior filing periods, the Form 502 may be filed online at, where instructions for completing the form also may be found.

Please do not hesitate to contact us with any questions.

Tuesday, August 2, 2016

FCC Releases Notice of Proposed Rulemaking on Amendments to Part 20 Rules

The Commission released a Notice of Proposed Rulemaking (“Notice”) seeking comment on proposals to streamline and harmonize requirements for wireless licensees and applicants.  The Commission considers revising its Part 20 rules governing commercial mobile radio services (“CMRS”), eliminating Section 20.9, and making related rule changes.  The revisions are intended to eliminate the burden on applicants and licenses that want to operate on a non-CMRS basis to overcome the Section 20.9 presumption that their service offerings are intended to operate as CMRS.  The Commission does not intend to change any substantive CMRS regulatory policies with the proposals in the Notice.

The Commission seeks comment on its amendments to the Part 20 rules, and its conclusion to eliminate the CMRS presumption in Section 20.9 and replace it by allowing applicants and licensees to inform initial, modification or assignment applications of their regulatory status.  It also seeks comment on the following proposals, among others:

  • Shortening the period for application processing and lessening regulatory requirements for licenses and applicants;
  • Relying on Section 20.3, which defines CMRS, to ensure that the Commission will continue to  treat services operating as functionally equivalent to CMRS in the same way as CMRS, and remove processing differences across types of wireless applications;
  • Modifying or making corrective edits to certain definitions and cross-references within the rules to better define terms in Part 20;
  • Whether retaining Section 20.9(a)(14), which lays out the process for challenging whether a service is CMRS or not is necessary; and
  • Eliminating Section 20.7, which prescribes an “under-inclusive” list of services that fall within the definition of “mobile services.”
  • Any necessary changes to the FCC’s form (i.e., Form 603).

Comments are due 60 days after publication in the Federal Register.
Reply Comments are due 90 days after publication in the Federal Register.

Please contact us with any questions.

Monday, August 1, 2016

Agenda Released for August Open Meeting

The Commission has released the following Agenda for the August Open Meeting, scheduled for Thursday, August 4, 2016:

·         Implementation of the Twenty-First Century Communications and Video Accessibility Act of 2010:  The Commission will consider a Report and Order that would convert the National Deaf Blind Equipment Distribution program from a pilot to a permanent program.

·         Improvements to Benchmarks and Related Requirements Governing Hearing Aid-Compatible Mobile Handsets:  The Commission will consider a Report and Order that would implement changes to the scope of the wireless hearing aid compatibility rules.

·         Rates for the Interstate Inmate Calling Services:  The Commission will consider an Order on Reconsideration, responding to a petition filed by Michael S. Hamden, that would ensure that the rates for Inmate Calling Services (ICS) are just, reasonable, and fair and explicitly account for facilities’ ICS-related costs.

The Commission will also consider Media and General Counsel actions as a consent agenda that will not be presented individually.

The meeting is scheduled to begin at 10:30 am, and can be streamed live at

Please contact us with any questions.