September 26, 2022

Volume XII, Number 269


September 23, 2022

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Telecom Alert: Pole Attachment Rulemaking Deadline Extension; Rip-and-Replace Apps Approved; $4.3M in RDOF Fines; 988 Suicide Prevention Lifeline [Vol. XIX, Issue 30]

Pole Attachment Rulemaking Reply Deadline Extended

The FCC issued an Order last week granting in part an unopposed motion seeking an extension of time to file reply comments on the Second Further Notice of Proposed Rulemaking seeking to establish standards on pole attachment sharing costs (Vol. XIX, Issue 18).  The motion, filed by the American Public Power Association, Edison Electric Institute, National Rural Electric Cooperative Association, and Utilities Technology Council, argued that the reply comment deadline should be extended by 60 days due to the complexity of the issues raised and the volume of the filings in the docket.  The Commission agreed to extend the reply comment deadline by 30 days until August 26, 2022. 

Rip-and-Replace Applications Approved

The FCC issued a Public Notice last week announcing the approved applications for reimbursement submitted in the Secure and Trusted Communications Networks Reimbursement Program (“Reimbursement Program”) (Vol. XIX, Issue 7).  Since demand for the support exceeded the $1.9 billion congressional appropriation, the Commission prioritized applicants with 2 million or fewer customers.  These applicants submitted over $4.6 billion in cost estimates, so the Commission will allocate funding to these applicants on an equal prorated basis. 

$4.3 Million in RDOF Fines Proposed

Last week, the FCC issued a Notice of Apparent Liability for Forfeiture proposing fines against 73 applicants in the Rural Digital Opportunity Fund auction (“Auction 904”) (Vol. XIX, Issue 19) for defaulting on their bids between July 26, 2021 and March 10, 2022.  These applicants defaulted on their respective bids by withdrawing applications in certain areas or failing to meet deadlines and requirements required by the auction rules.  The bid defaults affected 1,702 census block groups with 129,909 estimated locations in 36 states.

988 Suicide Prevention Lifeline Transition

On July 16, the U.S. transitioned from the 10-digit National Suicide Prevention Lifeline number to the 988 three-digit dialing code (Vol. XIX, Issue 18).  The lifeline also links to the Veterans Crisis Line, and all telephone service and text providers in the U.S. and five major territories must provide access via the new code.

Casey Lide, Thomas Magee, Tracy Marshall, Kathlee Slattery Thompson, Sean Stokes, and Wesley Wright also contributed to this article.

© 2022 Keller and Heckman LLPNational Law Review, Volume XII, Number 206

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...