BloostonLaw Telecom Update Published by the Law Offices of Blooston, Mordkofsky, Dickens, Duffy & Prendergast, LLP [Selected portions reproduced here with the firm's permission.] www.bloostonlaw.com |
| Vol.
12, No. 20 |
May
20, 2009 |
Update On Broadband Stimulus Program The National Telecommunications and Information Administration (NTIA) and the Rural Utilities Service (RUS) have not yet issued the detailed procedures for broadband stimulus grant/loan applications. However, there is still a chance that applications could be due as early as June 30 (although the chances of that date drifting into late summer increase with each day). However, interested clients should move expeditiously to identify projects eligible for stimulus money, and to gather information for their application. Some of the main criteria to be used in assessing the applications include the following, and priority will be given: (1) to projects that serve unserved or underserved areas. (2) to "shovel ready" projects. (3) where the project will be fully funded upon grant of the stimulus money. (4) to projects that result in economic growth and job creation. (5) to projects that increase affordability of broadband access. (6) to projects that provide the greatest broadband speed to the greatest number of subscribers. (7) to projects that enhance service for health care delivery, education, or children to the greatest population of users in the area. (8) to projects that will not result in unjust enrichment as a result of support for non-recurring costs through another Federal program for service in the area.
Interested clients should assemble information showing the merits of their proposals under the above criteria, and should develop their budget, business case, and implementation plan, among other showings. Please contact Ben Dickens, Gerry Duffy, or Mary Sisak with any questions or for assistance in preparing an application. |
INSIDE THIS ISSUE - Porting interval text spells out one business day rule, defines “small providers.”
- FCC seeks comment on CMRS competition.
- FCC seeks comments on FY 2009 regulatory fees.
- FCC releases text of order extending section 214 obligations to interconnected VoIP providers.
- VITAL MEETINGS & DEADLINES.
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Porting Interval Text Spells Out One Business Day Rule, Defines “Small Providers” The FCC has released the text of its Report and Order (R&O) on Local Number Portability (LNP) porting interval and validation requirements that it adopted at last week’s open meeting (BloostonLaw Telecom Update, May 13). In the R&O, the Commission reduced the porting interval for simple wireline and simple intermodal port requests from four business days to one business day. Specifically, it required all entities subject to the LNP rules to complete simple wireline-to-wireline and simple intermodal port requests within one business day. In a related Further Notice of Proposed Rulemaking (FNPRM), the Commission sought comment on what further steps, if any, it should take to improve the process of changing providers. By “intermodal ports,” the FCC refers to: (1) wireline-to-wireless ports; (2) wireless-to-wireline ports; and (3) ports involving interconnected Voice over Internet Protocol (VoIP) service. Because interconnected VoIP service can be provided over various types of facilities, the FCC refers to all interconnected VoIP ports as “intermodal” irrespective of the facilities at issue. The FCC decided to leave it to the industry to work through the mechanics of this new one-day porting interval. In particular, it directed the North American Numbering Council (NANC) to develop new LNP provisioning process flows that take into account this shortened porting interval. In developing these flows, the NANC must address how a “business day” should be construed for purposes of the porting interval, and generally how the porting time should be measured. The NANC must submit these flows to the Commission no later than 90 days after the effective date of this Order. The FCC further concluded that nine months is sufficient time for affected entities to implement and comply with the one-business day porting interval, and therefore required all providers subject to the LNP rules to comply with the one-business day porting interval within nine months from the date that the NANC submits its revised provisioning flows to the Commission, except for “small providers.” The FCC believes that nine months provides adequate time for providers to make the necessary software changes and upgrades and to accommodate changes to internal processes and policies. Small providers: Small providers are required to implement the reduced porting interval of one business day for simple wireline and simple intermodal ports no later than 15 months from the date that the NANC submits its revised provisioning flows to the Commission. The FCC considers providers with fewer than 2 percent of the nation’s subscriber lines installed in the aggregate nationwide and Tier III wireless carriers, as defined in the E911 Stay Order, to be small providers. What constitutes a 2 percent provider will be calculated based on an aggregate of incumbent LEC and competitive local exchange carrier (LEC) lines, based on the Commission’s most recent industry statistics available as of the effective date of this Order. In the E911 Stay Order, the Commission classified Commercial Mobile Radio Service (CMRS) carriers with 500,000 subscribers or fewer as of the end of 2001 as Tier III wireless carriers. The FCC believes that these categories encompass the providers whose systems will most likely require significant upgrades, and who also may have limited resources to make those upgrades. Thus, these providers may require the extended 15-month implementation period. FNPRM: In light of the actions taken in the Order, the FCC asks commenters to refresh the record on what further steps the Commission should take, if any, to improve the process of changing providers and provide any new ideas that reflect and build upon the new one-business day interval. The FCC asks parties to address whether there are additional ways to streamline the number porting processes or improve efficiencies for simple and non-simple ports. For example, should the Commission modify the definition of simple ports? Are different or additional information fields necessary for completing simple ports? Is it appropriate to standardize Local Service Request (LSR) forms and, if so, how should that be accomplished? Is a single standard time interval in which providers must return Customer Service Record (CSR) requests appropriate? Finally, what are the benefits and burdens, especially the burdens on small entities, of adopting any new rules regarding the porting process? Comments in this WC Docket No. 07-244 proceeding will be due 30 days after publication of the item in the Federal Register, and replies will be due 30 days thereafter. H.R. 2357: Rep. Mary Bono Mack (R-Calif.) has introduced H.R. 2357, the Same Number Act of 2009, which would reduce the wireline and intermodal porting interval to 48 hours. Similar bills were introduced in the last Congress but did not garner support. The FCC’s Order likely will preempt any legislative action. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. FCC Seeks Comment On CMRS Competition The FCC is soliciting data and information to evaluate the state of competition among providers of commercial mobile radio services (CMRS) for its 14th Annual Report and Analysis of Competitive Market Conditions with Respect to Commercial Mobile Services. In the five most recent CMRS Reports, the Commission has reviewed competitive market conditions using a framework that groups indicators into four categories: (1) market structure; (2) provider conduct; (3) consumer behavior; and (4) market performance. Accordingly, when submitting responses to this Public Notice, commenters should, to the extent possible, present materials addressing these four categories of indicators. The FCC seeks comment generally on which indicators are useful for analyzing competitive market conditions with respect to CMRS. The FCC requests comment on what specific criteria should be used to determine whether there is “effective competition” among CMRS providers. Industry members, members of the public, and other interested parties are encouraged to submit information, comments, and analyses regarding competition in the provision of CMRS. Commenters desiring confidential treatment of their submissions should request that their submission, or a specific part thereof, be withheld from public inspection. In order to facilitate its analysis of competitive trends over time, the FCC requests that parties submit current data as well as historic data that are comparable over time. Comments in this WT Docket No. 09-66 proceeding are due June 15, and replies are due June 29. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Cary Mitchell. FCC Seeks Comments On FY 2009 Regulatory Fees The FCC has asked for comment on the development of fiscal year (FY) 2009 regulatory fees collected pursuant to section 9 of the Communications Act. For FY 2009, the FCC proposes to retain the established methods and policies that it has used to collect regulatory fees in the past except for certain proposed changes. For the FY 2009 regulatory fee cycle, it proposes to retain most of the administrative measures used for notification and assessment of regulatory fees of previous years. However, as discussed below, the FCC is proposing to make use of its Fee Filer System mandatory, which could create burdens for smaller businesses—especially those without Internet access. Comments in this MD Docket No. 09-65 proceeding are due June 4, and replies are due June 11. The Commission is obligated to collect $341,875,000 in regulatory fees during FY 2009 to fund the Commission’s operations. Consistent with its established practice, it intends to collect these fees in the August-September 2009 time frame in order to collect the required amount by the end of the fiscal year. Fee Filer Proposals: This year, the FCC seeks comment on whether it should require all regulatees to enter critical information in the Fee Filer System, even if they do not pay through Fee Filer. In the past, the FCC has strongly encouraged regulatees to electronically file their regulatory fee payments via Fee Filer, instead of submitting payment with a completed hardcopy Form 159, Form 159-B, or Form 159-W. Although the FCC strongly urged the use of Fee Filer, it has not required it. By using the Fee Filer system, even if the regulatee does not pay electronically, certain information will be entered into its system by the regulatee, such as the FRN, a correct address, and key electronic data attributes such as a call sign, payment amount, fee code, and quantity of subscribers. By instituting a mandatory filing requirement (but not a mandatory electronic payment requirement), the FCC believes this will reduce errors resulting from illegible handwriting on hardcopy Form 159’s as well as create an electronic record of licensees who have paid regulatory fees. For those licensees who use the Commission’s electronic payment system, but who choose to mail in their payments using the Form 159-E voucher generated by Fee Filer, the Commission will have an electronic record of licensee payment attributes that are more easily traced than those payments that are simply mailed in with a hardcopy Form 159. Those who file and pay through Fee Filer are also certifying to the accuracy of their payment, their subscriber count, and their revenue amount. Although the FCC does not propose at this time to require payment through Fee Filer, it strongly encourages regulatees to do so. The FCC thinks there are many benefits: 1) expeditious submission of payment; 2) no postage or courier costs; 3) fewer errors caused by illegible handwriting or payments submitted without an FRN number or the appropriate data attributes (e.g., payers will avoid false delinquencies due to payment submission errors); 4) improved record keeping and payment reconciliation; 5) reduced administrative burden on both licensees and on Commission staff trying to process regulatory fee payments; 6) less expensive than a wire transfer; and 7) a significant reduction in the use of payment remittance forms such as Form 159-C’s submitted in support of a regulatory fee payment. These benefits will not only reduce the paper burden on licensees, but the administrative burden of preparing and mailing such documents. For regulatees who choose not to pay online, such as those licensees whose credit card transactions exceed $99,999.99, Fee Filer also provides an opportunity to make a payment using your bank account, also known as an Automated Clearing House (ACH) payment, or generating an electronic remittance voucher form (Form 159-E) that can be printed directly from Fee Filer and mailed in with a check. ACH payments do not have restrictions on the amount remitted. The FCC tentatively concludes that it should require regulatees to file key information into Fee Filer, even if they do not use Fee Filer to make their payment. In instances where payment cannot be made using Fee Filer, which include credit card transactions exceeding $99,999.99, wire transfers, and licensees wishing to pay using a check, the FCC proposes that those licensees still enter the Fee Filer system in order to generate a Form 159-E remittance voucher to accompany their payment. The FCC seeks comment on this proposal. Commenters opposing the mandatory Fee Filer requirement should provide the reasons for their argument, and should provide supporting facts and other data, particularly with respect to any claimed burdens of this approach. CMRS: Commercial Mobile Radio Service (CMRS) Messaging Services, which replaced the CMRS One-Way Paging fee category in FY 1997, includes all narrowband services. The FCC has maintained the CMRS Messaging Service regulatory fee at the rate that was first established in FY 2002, $0.08 per subscriber, because the subscriber base in this industry has declined significantly. The FCC found that maintaining the CMRS Messaging regulatory fee rate at $0.08 per subscriber, rather than allowing it to increase, was the appropriate level of relief to be afforded to the messaging industry. The FCC proposes to maintain the messaging service regulatory fee at $0.08 per subscriber. The FCC seeks comment on this proposal. [emphasis added] Comments of Acting Chairman Copps: In his statement, Acting Chairman Copps noted that the while the FCC is not proposing major changes to its regulatory fee structure, which is based upon the telecommunications market place as it existed in 1994, he will press the FCC for action before the FCC issues next year’s Regulatory Fee Notice of Proposed Rulemaking. Copps noted further that he does not have a vision as to what the new program would look like, but that he expects it to accurately and equitably reflect today’s regulatory practices. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino. FCC RELEASES TEXT OF ORDER EXTENDING SECTION 214 OBLIGATIONS TO INTERCONNECTED VOIP PROVIDERS: The FCC has released the text of its order extending to providers of interconnected Voice over Internet Protocol (VoIP) service the discontinuance obligations that apply to domestic non-dominant telecommunications carriers under section 214 of the Communications Act (BloostonLaw Telecom Update, May 13). Consequently, before an interconnected VoIP provider may discontinue service, it must comply with the streamlined discontinuance requirements under Part 63 of the Commission’s rules, including the requirements to provide written notice to all affected customers, notify relevant state authorities, and file an application for authorization of the planned discontinuance with the Commission. The FCC, however, does not impose any economic regulation on providers of interconnected VoIP service. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. FCC EXTENDS PART 36 FREEZE UNTIL JUNE 30, 2010; REFERS ISSUES TO JOINT BOARD: The FCC has extended the existing freeze of Part 36 category relationships and jurisdictional cost allocation factors until June 30, 2010. The Commission said that extending the freeze will provide stability for carriers that must comply with the FCC’s separations rules while issues related to comprehensive, permanent reform are considered. The FCC also referred to the Federal-State Joint Board on Separations review of the Commission’s jurisdictional separations rules to consider how the rules can be effectively reformed and asked the Joint Board to prepare a recommended decision. The FCC has asked the Joint Board to consider (1) the effects of any proposed separations reform on broadband deployment; (2) whether, in lieu of Part 36 usage studies, there should be a limited number of fixed jurisdictional cost allocation factors, or a single fixed factor; (3) the circumstances under which carriers should no longer be subject to jurisdictional separations, and to consider whether allowing carriers a one-time opportunity to freeze or unfreeze category relationships is warranted under the circumstances. Pursuant to FCC rules, 25 percent of cable and wire facilities Category 1 costs for subscriber or common lines that are jointly used for local exchange service and exchange access for state and interstate interexchange services are assigned to the interstate jurisdiction, with the remaining 75 percent assigned to the intrastate jurisdiction. The FCC asks the Joint Board to consider whether this allocation factor is reasonable. If the Joint Board concludes that it is not, the FCC asks it to consider what a more reasonable allocation factor would be. The Commission has recently considered a variety of measures regarding intercarrier compensation and universal service reform. Many commenters have suggested that it may be prudent to defer comprehensive reform of the jurisdictional separations rules until the Commission adopts reform in these areas. The FCC asks the Joint Board to consider whether such a deferral is in the public interest. If the Joint Board recommends deferring comprehensive jurisdictional separations reform, the FCC asks the Joint Board to consider a modification of the existing freeze, under which carriers could, for example, be required to modify category relationships and/or jurisdictional cost allocation factors, which would then be refrozen pending the outcome of the other proceedings. The FCC asks the Joint Board to consider the criteria that would be used for the recalculation of category relationships and jurisdictional cost allocation factors. For example, would usage studies be required, or would it be reasonable to determine category relationships based upon an analysis of revenue? BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. JUNE 1: FCC FORM 395, EMPLOYMENT REPORT. Common carriers, including wireless service providers, with 16 or more full-time employees must file their annual Common Carrier Employment Reports (FCC Form 395) by May 31. (But since May 31 falls on a Sunday this year, the report is due June 1.) This report tracks carrier compliance with rules requiring recruitment of minority employees. Further, the FCC requires all common carriers, regardless of the number of employees, to report any employment discrimination complaints they received during the past year. That information is also due on May 31. The FCC encourages carriers to complete the discrimination report requirement by filling out Section V of Form 395, rather than submitting a separate report. Clients who would like assistance in filing Form 395 should contact Richard Rubino. JUNE 30: ANNUAL ICLS USE CERTIFICATION. Rate of return carriers and CETCs must file a self-certification with the FCC and the Universal Service Administrative Company (USAC) stating that all Interstate Common Line Support (ICLS) and Long Term Support (LTS) will be used only for the provision, maintenance, and upgrading of facilities and services for which the support is intended. In other words, carriers are required to certify that their ICLS and LTS support is being used consistent with Section 254(e) of the Communications Act. Failure to file this self-certification will preclude the carrier from receiving ICLS support. We, therefore, strongly recommend that clients have BloostonLaw submit this filing and obtain an FCC proof-of-filing receipt for client records. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. JULY 10: DTV EDUCATION REPORT. New 700 MHz licensees from Auction No. 73 are required to file a report with the FCC concerning their efforts to educate consumers about the upcoming transition to digital television (DTV). Last summer, we explained that the FCC’s Part 27 rules require 700 MHz licensees that won licenses in Auction No. 73 to file quarterly reports on their DTV consumer outreach efforts through the Spring of 2009. However, in an apparent contradiction, the same rules do not impose any substantive consumer education requirements on 700 MHz license holders. This situation has not changed. The reporting rule simply states that “the licensee holding such authorization must file a report with the Commission indicating whether, in the previous quarter, it has taken any outreach efforts to educate consumers about the transition from analog broadcast television service to digital broadcast television service (DTV) and, if so, what specific efforts were undertaken.” Many licensees may not have initiated 700 MHz service as of yet. However, to the extent they are also an Eligible Telecommunications Carrier (ETC) and recipient of federal USF funds, separate FCC rules found in 47 C.F.R. Part 54 (Universal Service) require ETCs to send monthly DTV transition notices to all Lifeline/Link-Up customers (e.g., as part of their monthly bill), and to include information about the DTV transition as part of any Lifeline or Link-Up publicity campaigns until June 30, 2009. BloostonLaw contacts: Hal Mordkofsky and Cary Mitchell. JULY 20: FCC FORM 497, LOW INCOME QUARTERLY REPORT. This form, the Lifeline and Link-Up Worksheet, must be submitted to the Universal Service Administrative Company (USAC) by all eligible telecommunications carriers (ETCs) that request reimbursement for participating in the low-income program. The form must be submitted by the third Monday after the end of each quarter. It is available at: www.universalservice.org. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. JULY 31: FCC FORM 507, UNIVERSAL SERVICE QUARTERLY LINE COUNT UPDATE. Line count updates are required to recalculate a carrier's per line universal service support, and is filed with the Universal Service Administrative Company (USAC). This information must be submitted on July 31 each year by all rate-of-return incumbent carriers, and on a quarterly basis if a competitive eligible telecommunications carrier (CETC) has initiated service in the rate-of-return incumbent carrier’s service area and reported line count data to USAC in the rate-of-return incumbent carrier’s service area, in order for the incumbent carrier to be eligible to receive Interstate Common Line Support (ICLS). This quarterly filing is due July 31 and covers lines served as of December 31, 2007. Incumbent carriers filing on a quarterly basis must also file on September 30 (for lines served as of March 31, 2008); December 30 (for lines served as of June 30, 2008), and March 31, 2009, for lines served as of September 30, 2008).. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. JULY 31: FCC FORM 525, COMPETITIVE CARRIER LINE COUNT QUARTERLY REPORT. Competitive eligible telecommunications carriers (CETCs) are eligible to receive high cost support if they serve lines in an incumbent carrier’s service area, and that incumbent carrier receives high cost support. CETCs are eligible to receive the same per-line support amount received by the incumbent carrier in whose study area the CETC serves lines. Unlike the incumbent carriers, CETCs will use FCC Form 525 to submit their line count data to the Universal Service Administrative Company (USAC). This quarterly report must be filed by the last business day of March (for lines served as of September 30 of the previous year); the last business day of July (for lines served as of December 31 of the previous year); the last business day of September (for lines served as of March 31 of the current year); and the last business day of December (for lines served as of June 30 of the current year). CETCs must file the number of working loops served in the service area of an incumbent carrier, disaggregated by the incumbent carrier’s cost zones, if applicable, for High Cost Loop (HCL), Local Switching Support (LSS), Long Term Support (LTS), and Interstate Common Line Support (ICLS). ICLS will also require the loops to be reported by customer class as further described below. For Interstate Access Support (IAS), CETCs must file the number of working loops served in the service area of an incumbent carrier by Unbundled Network Element (UNE) zone and customer class. Working loops provided by CETCs in service areas of non-rural incumbents receiving High Cost Model (HCM) support must be filed by wire center or other methodology as determined by the state regulatory authority. CETCs may choose to complete FCC Form 525 and submit it to USAC, or designate an agent to file the form on its behalf. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. JULY 31: REPORT OF EXTENSION OF CREDIT TO FEDERAL CANDIDATES. This report (in letter format) must be filed by January 30 and July 31 of each year, but ONLY if the carrier extended unsecured credit to a candidate for a Federal elected office during the reporting period. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino. AUGUST 1: FTC BEGINS ENFORCEMENT OF RED FLAG RULES. The Federal Trade Commission (FTC) has delayed enforcement of the “Red Flag” Rules for 90 days until August 1, 2009, to give creditors and financial institutions additional time to implement identity theft programs. Under the new rules, all businesses that maintain a creditor-debtor relationship with customers, including virtually all telecommunications carriers (but other companies as well), must adopt written procedures designed to detect the relevant warning signs of identity theft, and implement an appropriate response. The Red Flag compliance program was in place as of November 1, 2008. But the FTC will not enforce the rules until August 1, 2009, meaning only that a business will not be subject to enforcement action by the FTC if it delays implementing the program until August 1. The FTC announcement does not affect other federal agencies’ enforcement of the original Nov. 1, 2008, compliance deadline for institutions subject to their oversight. Other liabilities may be incurred if a violation occurs in the meantime. The requirements are not just binding on telcos and wireless carriers that are serving the public on a common carrier basis. They also apply to any “creditor” (which includes entities that defer payment for goods or services) that has “covered accounts” (accounts used mostly for personal, family or household purposes). This also may affect private user clients, as well as many telecom carriers’ non-regulated affiliates and subsidiaries. BloostonLaw has prepared a Red Flag Compliance Manual to help your company achieve compliance with the Red Flag Rules. Please contact Gerry Duffy (202-828-5528) or Mary Sisak (202-828-5554) with any questions or to request the manual. AUGUST 3: FCC FORM 499-Q, TELECOMMUNICATIONS REPORTING WORKSHEET. All telecommunications common carriers that expect to contribute more than $10,000 to federal Universal Service Fund (USF) support mechanisms must file this quarterly form. (Normally this form is due on August 1, but because August 1 falls on a Saturday this year, the next business day is Monday, August 3.) This filing requirement also applies to certain Private Mobile Radio Service (PMRS) licensees, such as for-profit paging and messaging, dispatch and two-way mobile radio services. The FCC has modified this form in light of its recent decision to establish interim measures for USF contribution assessments. The form contains revenue information from the prior quarter plus projections for the next quarter. Form 499-Q relates only to USF contributions. It does not relate to the cost recovery mechanisms for the Telecommunications Relay Service (TRS) Fund, the North American Numbering Plan Administration (NANPA), and the shared costs of local number portability (LNP), which are covered in the annual form (Form 499-A) that was due April 1. For-profit private radio service providers that are “de minimis” (those that contribute less than $10,000 per year to the USF) do not have to file the 499-A or 499-Q. However, they must fill out the form and retain the relevant calculations as well as documentation for their contribution base revenues for three years. De minimis telecom carriers must actually file the Form 499A, but not the 499Q. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. AUGUST 3: FCC FORM 502, NUMBER UTILIZATION AND FORECAST REPORT: Any wireless or wireline carrier (including paging companies) that have received number blocks—including 100, 1,000, or 10,000 number blocks—from the North American Numbering Plan Administrator (NANPA), a Pooling Administrator, or from another carrier, must file Form 502 by August 3. (Normally, this filing would be due August 1, but this year August 1 falls on a Saturday, and FCC rules require the filing be submitted the first business day thereafter.) Carriers porting numbers for the purpose of transferring an established customer’s service to another service provider must also report, but the carrier receiving numbers through porting does not. Resold services should also be treated like ported numbers, meaning the carrier transferring the resold service to another carrier is required to report those numbers but the carrier receiving such numbers should not report them. New this year is that reporting carriers are required to include their FCC Registration Number (FRN). Reporting carriers file utilization and forecast reports semiannually on or before February 1 for the preceding six-month reporting period ending December 31, and on or before August 1 for the preceding six-month reporting period ending June 30. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. VITAL MEETINGS & DEADLINES May 22 – Deadline for reply comments on price cap carriers’ short form TRP associated with annual access tariff filing due July 1. May 26 – Deadline for reply comments on Iowa Telecom request for waiver of Section 61.41 “all or nothing” rule regarding acquisitions of Lakedale and Sherburne (WC Docket No. 09-25). May 29 – Deadline for reply comments on unassigned BRS auction spectrum (Auction No. 86) practices and procedures (AU Docket No. 09-56). May 29 – Deadline for comments on conservation groups’ request for FCC action on antenna structures (WT Docket Nos. 08-61, 03-187). May 31 – FCC Form 395, Employment Report, is due. June 3 – FCC open meeting. June 4 – Deadline for comments on FY 2009 regulatory fees (MD Docket No. 09-65). June 8 – Deadline for reply comments on NOI to refresh record on non-rural USF support mechanism (WC Docket No. 05-337). June 8 – Deadline for comments on NOI seeking comment on developing national broadband plan (GN Docket No. 09-51). June 11 – Deadline for reply comments on FY 2009 regulatory fees (MD Docket No. 09-65). June 12 – DTV Transition. June 13 – DTV Analog Nightlight program begins and runs for 30 days until July 12. June 15 – Deadline for reply comments on conservation groups’ request for FCC action on antenna structures (WT Docket Nos. 08-61, 03-187). June 15 – Deadline for comments on 14th Annual Report on CMRS Competition (WT Docket No. 09-66). June 16 – Deadline for ILECs filing annual access tariffs on 15 days’ notice (carriers proposing to increase any of their rates). June 19 – Deadline for both paper and electronic copies of applications for FY 2009 RUS Community Connect Grants for broadband projects. June 23 – Deadline for petitions to suspend or reject annual access tariffs filed on 15 days’ notice (by carriers proposing to increase any of their rates). June 24 – Deadline for ILECs filing annual access tariffs on seven day’s notice (carriers proposing to decrease all of their rates). June 26 – Deadline for petitions to suspend or reject annual access tariffs filed on seven day’s notice (by carriers proposing to decrease all of their rates). |
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