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Volume XII, Number 273


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Telecom Alert: Annual CPNI Certifications; Rip-and-Replace Applications; EAS Pleading Cycle; Emergency Connectivity Fund [Vol. XIX, Issue 7]

Annual CPNI Certifications Due March 1

The FCC issued an Enforcement Advisory last week reminding telecommunications carriers and interconnected VoIP providers of their obligation to file their annual certification documenting compliance with the Customer Proprietary Network Information rules (“CPNI”) by March 1, 2022.  CPNI includes sensitive personal information about customers, and the Commission’s rules seek to ensure that CPNI is adequately protected from unauthorized access.  Failure to comply with the requirements may lead to enforcement action, including monetary forfeitures of up to $220,213 for each violation or each day of a continuing violation, up to a maximum of $2,202,123. 

Rip-and-Replace Applications Announced

Last week, the Wireline Competition Bureau released a Public Notice announcing the applications filed for the Secure and Trusted Communications Networks Reimbursement Program (the “Program”) (Vol. XVIII, Issue 32).  The Bureau received 181 applications, of which 162 have been initially found acceptable for filing.  The gross cost estimate demand for support from the $1.9 billion Program is nearly $5.6 billion.  The Bureau also extended the application review period by an additional 45 days, moving the deadline for acting on the submitted applications to June 15, 2022.  

Emergency Alert System Pleading Cycle

The FCC’s Notice of Proposed Rulemaking and Notice of Inquiry seeking comment on ways to improve the clarity and accessibility of the visual message associated with the nationwide tests of the Emergency Alert System (“EAS”) was published in the Federal Register last week.  The Commission proposes using a predetermined script as the visual message for legacy EAS nationwide tests and revising associated terminology to improve clarity.  Comments and reply comments are due by March 11, 2022, and March 28, 2022, respectively.  

 Nearly $126 Million in Emergency Connectivity Fund Committed

The FCC announced it is committing $125,962,023.72 in the latest round of the Emergency Connectivity Fund.  This round of commitments will support 340 schools, 20 libraires, and 6 consortia, which are approved to receive over 330,000 connected devices and over 39,000 broadband connections.  The fund has committed over $4.5 billion since it was launched.  

Gregory E. KunkleCasey LideThomas B. MageeTracy P. MarshallKathleen Slattery ThompsonSean A. Stokes and Wesley K. Wright contributed to this article.

© 2022 Keller and Heckman LLPNational Law Review, Volume XII, Number 45

About this Author


Jaimy “Sindy” Alarcon is a Federal Communications Commission (FCC) and Federal Aviation Administration (FAA) Licensing Specialist.

Sindy works in conjunction with the attorneys in the Telecommunications Practice to prepare FCC applications for clients seeking authority for new services, modifications, administrative updates, license cancellations, Requests for Special Temporary Authority (STA), Requests for Rule Waivers, Assignments of Authorization, Transfers of Control, Renewals, and Notifications of Construction for various radio services including microwave, land mobile, marine...

Jim Baller Communications Attorney Keller & Heckman Washington, DC

James (Jim) Baller represents clients across the U.S. in a broad range of communications matters including high-capacity broadband network projects, public-private broadband partnerships, telecommunications, wireless facility siting, right-of-way management, pole and conduit attachments, and barriers to community broadband initiatives.

Jim was the founder and president of the U.S. Broadband Coalition, a diverse group of more than 160 communications service providers, high technology companies, labor unions, public interest and consumer groups, state and local government entities,...

Law Graduate

Jason Chun is a Law Graduate with our Telecommunications practice (not yet licensed to practice law as he awaits admittance under the D.C. Bar's Emergency Examination Waiver).

Timothy A. Doughty, Keller Heckman, Telecommunications Licensing Specialist, Lawyer, FCC Matters Attorney

Timothy Doughty joined Keller and Heckman in 2009 as a Federal Communications Commission (FCC) Licensing Specialist.

Mr. Doughty assists clients with the preparation of FCC applications, modifications, special temporary authorities, requests for rule waiver, renewals and spectrum leases in various radio services including Private Land Mobile, Microwave, Coast and Ground and Aircraft. His capabilities also include the preparation of tower registrations with the FCC and Obstruction Evaluations and Aeronautical Studies with the Federal Aviation...

C. Douglas Jarrett, Keller Heckman, telecommunications lawyer, procurement law

Douglas Jarrett joined Keller and Heckman in 1979. Mr. Jarrett specializes in telecommunications law, policy and procurement matters.

Mr. Jarrett is a recognized expert in representing enterprises in negotiating telecommunications services agreements with the major wireline and wireless carriers, domestically and globally.  He also advises enterprises on M2M services, cloud computing and IVR technology procurements. 

Mr. Jarrett represents technology companies in securing amendments to the FCC rules to enable the...