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Telecom Alert – C-Band Certifications Due Today; 911 Location Accuracy FNPRM; LIFT American Act Broadband Funding; NAL for FAA Weather Radar Interference; UTC – Vol. XVI, Issue 21

C-Band Certifications Due Today

The filing window for certifications in the 3.7 GHz – 4.2 GHz band (C-Band) closes today, May 28, 2019.  The Commission’s Public Notice on the matter requires all operators of FSS earth stations in the C-Band that are licensed or registered in the International Bureau Filing System (IBFS) to certify the accuracy of all information reflected on their license (Vol. XVI, Issue 20).  The certification must include the relevant Call Signs, file numbers, applicant or registrant name, as well as a certification statement that the information on the license is complete and correct.  

911 Location Accuracy FNPRM Comments

On May 20, 2019, the filing window closed for Comments on the FCC’s Fourth Further Notice of Proposed Rulemaking on 911 Location Accuracy rules.  The proceeding aims to make it easier for first responders to accurately locate individuals making a wireless 911 call from a multistory building by assisting 911 call centers in identifying the floor where the call occurs (Vol. XVI, Issue 11).  Specifically, the Fourth FNPRM proposed a vertical accuracy metric of plus or minus three meters.  Commenters largely agreed with the accuracy metric, but disagreed on how requirements for the metric should be implemented.  Wireless carriers generally raised concerns about requirements for technology, and some questioned whether technology exists to meet the Commission’s accuracy standards. 

LIFT America Act Broadband Funding

On May 15, 2019, all Democrat Members of the House Energy and Commerce Committee introduced the Leading Infrastructure For Tomorrow’s (LIFT) America Act, which funds a variety of infrastructure projects.  The bill promotes broadband infrastructure by providing $40 billion for deployment to expand access to broadband, $12 billion in grants for NG 911 deployment, and $5 billion in low interest loans to finance broadband projects.  On May 22, 2019, the Committee held a hearing to discuss the bill.  Members agreed funding is needed, but many called for more accurate broadband mapping to more efficiently allocate limited funding.  Former FCC Commissioner Mignon Clyburn testified at the hearing, agreeing that maps need to be updated and stating that the FCC must complete its proceeding to update Form 477 to more accurately gather broadband data.  

FCC Proposes $20,000 Fine for Interfering with FAA Weather Radar

The Commission issued a Notice of Apparent Liability (NAL) proposing a fine of $20,000 against Caribbean Network Solutions, Inc.  The NAL states that Caribbean Network was “operating two Unlicensed National Information Infrastructure (U-NII) devices without a license, in a manner inconsistent with the Commission’s rules.”  The operations caused interference to an FAA terminal doppler weather radar station in San Juan, Puerto Rico.  The FAA uses terminal doppler weather radar to detect dangerous weather conditions near airports.  The NAL states that Caribbean Network was willfully violating the Commission’s rules. 

© 2020 Keller and Heckman LLP


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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. 

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Gregory E. Kunkle, Keller Heckman, regulatory attorney, FCC lawyer

Gregory Kunkle joined Keller and Heckman in 2006. Mr. Kunkle practices in the area of telecommunications, with an emphasis on assisting corporate clients and trade associations with various legal and regulatory matters before the Federal Communications Commission.

Mr. Kunkle regularly counsels critical infrastructure companies, such as electric utilities, oil and gas companies, and railroads, public safety agencies, and commercial providers regarding FCC wireless licensing and compliance issues.  He assists clients in identifying and acquiring wireless spectrum through a variety of means, including spectrum leasing, purchase and sale of licenses, and the FCC's auction process. His spectrum acquisition practice spans all of the FCC’s wireless frequency allocations, including the 220 MHz band, AMTS (217/219 MHz), VHF/UHF Part 22 Paging, the 1.4 GHz band, Part 90 800/900 MHz bands, MAS, the 2.5 GHz EBS/BRS band, and the 700 MHz band.

Mr. Kunkle counsels clients that become involved in the FCC's enforcement process including by responding to and vigorously defending against complaints and investigations and, where appropriate, negotiating settlements with the Commission. 

Thomas B. Magee, Keller Heckman, transactional counsel, litigation attorney, FCC law, safety violation lawyer

Thomas Magee joined Keller and Heckman in 2000. Mr. Magee provides regulatory, transactional and litigation counsel to investor-owned electric utilities, electric cooperatives and municipalities regarding pole attachments and Federal Communications Commission (FCC) licensing of private wireless telecommunications services.

Mr. Magee has helped to resolve dozens of pole attachment disputes affecting make-ready costs, safety violations, unauthorized attachments, annual rental rates and other terms and conditions of access. He negotiates,...

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Tracy Marshall assists clients with a range of business and regulatory matters.

In the business and transactional area, Ms. Marshall advises for-profit and non-profit clients on corporate organization, operations, and governance matters, and assists clients with structuring and negotiating a variety of transactions, including purchase and sale, marketing, outsourcing, and e-commerce agreements.

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Wesley K. Wright, Keller Heckman, Telecommunications Lawyer, FCC Enforcement Attorney, DC

Wesley Wright joined Keller and Heckman in 2006 and practices in the areas of telecommunications law.  He assists corporate clients and trade associations with various legal and regulatory matters before the Federal Communications Commission, Federal Aviation Administration, courts and state agencies.

Mr. Wright’s practice includes private wireless licensing, FCC enforcement, and related transactional matters.  He counsels clients on internal operations and governance matters and has drafted and negotiated asset purchase agreements,...