October 3, 2022

Volume XII, Number 276


October 03, 2022

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Telecom Alert: Pole Attachment Rulemaking Pleading Cycle; Spectrum Innovation Act; ECF Third Filing Window; 988 Geolocation Forum [Vol. XIX, Issue 18]

Pole Attachment Rulemaking Pleading Cycle

The FCC’s Second Further Notice of Proposed Rulemaking seeking to establish standards on pole attachment sharing costs was published in the Federal Register.  The Commission requests input on whether it should adopt guidelines for when and how utilities should be required to pay a proportional share of the total pole replacement costs, and the scope of refund liability to pole owners. Comments and reply comments are due on June 27, 2022, and July 27, 2022, respectively (Vol. XIX, Issue 12). 

Spectrum Innovation Act Introduced

On April 28, Senators Ben Ray Lujan (D-NM) and John Thune, along with Representatives Mike Doyle (D-PA) and Bob Latta (R-OH) introduced the Spectrum Innovation Act of 2022, which would make mid-band spectrum available for wireless broadband use. Specifically, the bill would require at least 200 MHz in the 3.1-3.45 GHz band to be auctioned for non-federal use, shared federal and non-federal use, or a combination of the two.  It would also transfer $50 million from the Spectrum Relocation Fund for a federal entity to plan for spectrum use.

Emergency Connectivity Fund Third Filing Window

Last week, the FCC announced that it will be opening a third application filing window in the Emergency Connectivity Fund (“ECF”) to award at least $1 billion to schools and libraries (Vol. XIX, Issue 17).  Applicants can submit requests beginning April 28, 2022 until May 13, 2022 for funding to purchase eligible equipment and services.  Given past demand, this filing window will likely be the last opportunity to request funding before the ECF is exhausted.

988 Geolocation Forum

Last week, the FCC announced that it will hold a forum in conjunction with the U.S. Department of Health and Human Services and the U.S. Department of Veterans Affairs on the challenges and opportunities related to geolocation for 988, the three-digit number designated for the National Suicide Prevention Lifeline (Vol. XVII, Issue 47).  The forum, which will be held on May 24, 2022, will include panels and discussions with state and local stakeholders, suicide prevention and mental health experts and advocates, communications industry leaders, and technical experts.  It is open to the public via a live feed on the FCC’s website.

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

© 2022 Keller and Heckman LLPNational Law Review, Volume XII, Number 122

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...