January 23, 2022

Volume XII, Number 23

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January 20, 2022

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Telecom Alert: FCC Proposes Changes to E-Rate Procedures; PSAP Do-Not-Call Registry Receives Negative Feedback; FCC Grants ECF Invoice Filing Deadline Waiver; EAS NPRM [Vol. XVIII, Issue 49]

FCC Proposes Changes to E-Rate Procedures

The FCC will consider a Notice of Proposed Rulemaking at its Open Meeting on December 14 that proposes several changes to the E-Rate program’s procedures.  Specifically, the Commission seeks comment on a proposal to implement a bidding portal though which service providers would be required to submit their bids, instead of directly to applicants.  The Commission also seeks comment on whether applicants should be required to provide other competitive bidding documentation, such as questions from bidders, as well as contract documents at the time they submit their funding applications to USAC.  

PSAP Do-Not-Call Registry Receives Negative Feedback

The FCC received several critical comments in response to the agency’s proposal to require voice service providers to block robocalls made to 911 call centers (Vol. XVIII, Issue 40).  The Commission’s proposal called for robocallers to submit their originating phone numbers to a registry so that service providers would know which numbers should be blocked.  NCTA argued that the FCC’s proposal would be ineffective and could potentially lead to blocking emergency calls made to 911.  USTelecom noted that such rules would be ineffective because bad actors could circumvent the rules by refusing to register numbers in the registry.  

FCC Grants ECF Invoice Filing Deadline Waiver

The Wireline Competition Bureau issued an Order last week granting the State E-rate Coordinators’ Alliance (“SECA”) petition for an expedited waiver of the Emergency Connectivity Fund (“ECF”) Program’s invoice filing deadline.  The Bureau is waiving the deadline to provide relief to applicants that (a) applied for ECF funding during the first or second application filing windows; (b) incorrectly used June 30, 2022 as the service delivery date on their Form 471 applications rather than the actual date; and (c) received a funding commitment decision letter or revised funding commitment decision letter noting August 29, 2022 as the invoice filing deadline.  For applicants that incorrectly used June 30, 2022 as the service delivery date but have not yet received an FCDL or RFCDL, June 30, 2022 will be used as the service delivery date.  

Emergency Alert System Visual Messages NPRM

The FCC will consider a Notice of Proposed Rulemaking and Notice of Inquiry at its December Open Meeting that seeks comment on proposals to improve the clarity and accessibility of the visual message associated with nationwide tests of the Emergency Alert System (“EAS”).  The Commission proposes requiring use of a predetermined script as the visual message for legacy EAS nationwide tests.  The Proposal would also revise the associated terminology to improve the clarity of these visual messages. Finally, the Commission seeks comment on how the legacy EAS architecture can be modified to enable alert originators to relay visual text that matches their audio message.

© 2022 Keller and Heckman LLPNational Law Review, Volume XI, Number 340
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About this Author

Casey Lide Communication Attorney Keller & Heckman Washington, DC
Partner

Casey Lide represents clients on a broad range of communications matters including telecommunications, cable television, broadband Internet access service, wireless communications, right-of-way management, pole and conduit attachments, and barriers to community broadband initiatives.

Casey counsels public- and private-sector clients on contract drafting and negotiation matters, including fiber optic IRUs and leases, easements, franchises, attachment agreements, ISP service agreements, interconnection and collocation agreements, strategic MoUs and others.   

He collaborates...

202-434-4186
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).

202-434-4491
Wesley K. Wright, Keller Heckman, Telecommunications Lawyer, FCC Enforcement Attorney, DC
Partner

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,...

202.434.4239
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