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A LESSON FOR PAGING SYSTEM OPERATORS FROM THE MILITARY

“Two is One and One is None: The Art of Redundancy”

When you hear the word “redundant,” you rarely think of anything good. Normally, this word is saved for things that waste your time and cause you to do the same thing twice. While this is true in some cases, redundancy in the world of survival isn’t only recommended, it’s required.

Take for example Teddy Roosevelt. Our future 26th president needed his glasses to see clearly, especially when in battle. Instead of trusting fate that his glasses would remain on his face and in tact, he often rode into battle with a dozen or more pairs of his glasses on his person, including at least one pair sewn into his hat! The battle at San Juan would have gone very differently for Roosevelt if he had brought only one pair, as his Rough Riders would have had a nearly blind leader sending them into battle.

The saying “Two is one and one is none” comes from the Navy Seals. This idea simply put means that only having one of something is the same as not having it at all and having two of any item is the same as what you think having one means. This applies to plans, supplies, weapons, and even clothing. If you have a single knife with you and you lose or break it, you might as well have not had it to begin with. Having a backup means that the inevitable loss or breakage won’t slow you down.

Having one of something important means you’re playing against fate to keep it working, and in a survival situation there’s no hardware or sporting goods store to go to for a replacement.

This doesn’t mean you need to have two of every single item you carry, but instead you need to build in redundancy for items that are vital to your survival. For example, you should have at least two knives with you at any time. This means if one breaks you have another close at hand. In your Bug Out Bag (BOB) you should have at least two fire-starting tools, and ideally 3 or more. Speaking of your BOB, you should have at least 2 compasses and maps as well as two or more flashlights . . . you get the idea. [source]

If you are a regular reader, you have heard this before, but since Rick McMichael of Preferred Wireless, will be closing his business by July 31st, I feel an obligation to remind everyone again that this may be your last chance to obtain critical replacement paging infrastructure equipment.

Rick has one of the largest stocks of paging infrastructure equipment in the world. An updated list of his inventory follows.

Remember: “One is none — two is one.”

Now on to more news and views.

Wayne County, Illinois

Emergency Radio Communications Wireless Messaging Critical Messaging Two-way Radio Technology Telemetry Science Paging Wi-Fi

Wireless Messaging

This doesn't mean that nothing is ever published here that mentions a US political party—it just means that the editorial policy of this newsletter is to remain neutral on all political issues. We don't take sides.

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There is no charge for subscription and there are no membership restrictions. Readers are a very select group of wireless industry professionals, and include the senior managers of many of the world’s major Paging and Wireless Messaging companies. There is an even mix of operations managers, marketing people, and engineers — so I try to include items of interest to all three groups. It’s all about staying up-to-date with business trends and technology.

I regularly get readers’ comments, so this newsletter has become a community forum for the Paging, and Wireless Messaging communities. You are welcome to contribute your ideas and opinions. Unless otherwise requested, all correspondence addressed to me is subject to publication in the newsletter and on my web site. I am very careful to protect the anonymity of those who request it.

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Editorial Opinion pieces present only the opinions of the author. They do not necessarily reflect the views of any of advertisers or supporters. This newsletter is independent of any trade association. I don't intend to hurt anyone's feelings, but I do freely express my opinions.

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Muncie Based ComNet, LLC Wins Coveted ATSI Award Of Excellence For 13th Time

ComNet owners, Mindy and Tom Kemper are pictured with their 13th ATSI award. Photo by: Mike Rhodes

JULY 12, 2017
By: Melanie Dixon—

Altamonte Springs, FL—ComNet, LLC of Muncie, IN has been honored with the exclusive ATSI 2017 Award of Excellence for the 13th year. This award is presented annually by the Association of TeleServices International (ATSI), the industry’s Trade Association for providers of telecommunications and call center services including telephone answering and message delivery across North America and the UK. ComNet, LLC was presented with the award at ATSI’s 2017 Annual Convention held at the Palmer House Hilton in Chicago, IL.

Independent judges are contracted by ATSI to evaluate message services over a six month period. The scoring criteria includes: Response time, courteousness of the rep, accuracy of the call, knowledge of the account, and overall impression of calls.

According to ATSI President Doug Robbins, “The ATSI Award of Excellence Program recognizes that excellence requires a level of service that considers the caller first in every aspect of the call. The award is earned by a company by judging the handling of calls placed by mystery callers against specific, member-driven criteria. Companies that earn this award are continuously focusing on delivering excellence in customer call handling. It is truly an honor.”

The award started 21 years ago as a means to improve the overall quality of the call center industry by setting expectations and measurements to ensure a successful call handling experience.

About ATSI

The Association of TeleServices International was founded in 1942 as a national Trade Association representing live answering services. ATSI now encompasses companies across North America and the UK offering specialized and enhanced operator based services including: call centers, contact centers, inbound telemarketing (order entry), paging, voice messaging, emergency dispatch, fax, and internet services among others.

About ComNet, LLC

ComNet, LLC is a Muncie based, family owned company providing 24-hour, 7-days-a-week web interactive call center services including telephone answering, inbound telemarketing, order entry, scheduling services, and commercial and residential voice-mail services. ComNet serves a variety of large companies and small businesses from Maine to California, and nearly everywhere in between. The entire team at ComNet provides the best possible messaging and related services. For more information visit: http://www.comnetmessage.com

Enhancing Mobile Alert Response

sales@wirelessmessaging.com
800-373-1466
2630 National Dr., Garland, TX 75041

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MARS (Mobile Alert Response System)

• Paging Protocol Monitoring and Wireless Sensor Monitoring (Inovonics and Bluetooth LE)
• Improves Mobile Response Team Productivity using Smartphone App
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• Automated E-mail Based Alert Response and System Status Reports
• Linux Based Embedded System with Ethernet and USB Ports
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• Mobile Resident Call and Wandering Resident Tracking with Bluetooth Beacons
• SMTP and SIP Inputs and XMPP Output in Development

STG (SIP to TAP Gateway)

• Monitors Rauland Nurse Call SIP Protocol
• Outputs TAP protocol to Ethernet and Serial Port Paging Systems
• Linux Based Embedded System
  
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Easy Solutions provides cost effective computer and wireless solutions at affordable prices. We can help in most any situation with your communications systems. We have many years of experience and a vast network of resources to support the industry, your system and an ever changing completive landscape.

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Experts in Paging Infrastructure

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Please see our web site for exciting solutions designed specifically for the Wireless Industry. We also maintain a diagnostic lab and provide important repair and replacement parts services for Motorola and Glenayre equipment. Call or e-mail us for more information.

INDUSTRY NEWS — TECHNOLOGY

Could this startup's lawsuit burst Alphabet’s balloon?

Jul 6, 2017, 2:02pm PDT
By Gina Hall, Contributor
Silicon Valley Business Journal

A scrappy startup could let the air out of Alphabet’s balloon.

Last summer, Arizona-based Space Data sued Alphabet’s X division over its Internet-beaming balloon initiative, Project Loon. Space Data claimed the Google parent company stole trade secrets after top executives from each company met in 2007 to discuss an acquisition.

Google founders Larry Page and Sergey Brin, in addition to other Google staffers, visited Space Data’s offices in 2008 and were given demonstrations of the company’s technology, per Fortune. But after acquisition talks fizzled, Google ramped up Project Loon.

Last month, Space Data finally persuaded the U.S. Patent and Trademark Office to cancel the majority of one of Project Loon’s foundational patents, according to a new report out from Wired. Space Data convinced officials that it, not Alphabet, came up with the idea to change a balloon’s direction by adjusting its altitude.

The patent is now in Space Data’s hands. Alphabet has never before had one of its 36,000 patents change hands because of “interference,” according to Wired. “Interference” is defined as when a patent describes the same invention as an earlier filing from another company.

Mountain View-based Alphabet will now have to face Space Data in court without a claim on the patent, which it was counting on to win the case.

Space Data started researching a paging service from high-altitude balloons back in 2000 and filed the disputed patent application in 2001. The company then went on to experiment with using the balloons to send texts, calls and 4G LTE. The company currently provides commercial wireless services from balloon constellations and operates a radio repeater platform employed by the US Army and Marine Corps that uses weather balloons.

This latest lawsuit is one of many headaches Google faces with Project Loon. In March, Project Loon CEO Alastair Westgarth stepped down after only six months on the job, handing the reins to Tom Moore.

The company has also scaled back Project Loon's original design. When Project Loon was first tested four years ago, the original idea was to use thousands of Wi-Fi-enabled balloons to fly around the world and form a connected chain that could beam Internet to any area where it didn't exist. In February 2017, Loon engineers announced it had deployed machine learning to create better flight patterns, which cut down the number of balloons needed and number of areas over which to fly.

Alphabet has also downsized several of its “moonshot” projects recently, including Project Titan, which would have used drones to beam Internet access to the ground, Terra Bella, which would have beamed Internet access from satellites, and high-speed Internet service group Google Fiber.

Over the last year, Alphabet's X unit has been under more pressure to turn experiments into viable businesses since the Google parent company started reorganizing its spending.

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Repair and Refurbishment Services

Product Support Services, Inc.

511 South Royal Lane
Coppell, Texas 75019
(972) 462-3970 Ext. 261
sales@pssirl.com
www.pssirl.com

PSSI is the industry leader in reverse logistics, our services include depot repair, product returns management, RMA and RTV management, product audit, test, refurbishment, re-kitting and value recovery.

BUSINESS / TECH

Pagers may make a comeback in Japan as emergency lifelines during disasters

KYODO JUL 3, 2017
The Japan Times

The powerful frequencies of pager devices are attracting attention as an improve d means of disseminating emergency information to the public when disasters occur.

Since the March 2011 earthquake and tsunami that hit the Tohoku region, a growing number of municipalities have been making use of the frequency bands used by pagers. The strength of these bands means signals can be received even inside buildings and in underground locations.

Pagers were especially popular among younger people in the 1990s, but their use sharply declined over the years due to the popularity of mobile phones and the personal handyphone system, or PHS.

During disasters, local governments mainly use a wireless system to broadcast crucial information. They transmit information using frequencies around 60 megahertz for broadcast via outdoor speakers, as well as through receivers set up in the homes of those who consent to install them.

But the 20-cm-long, 25-cm-wide receiver is costly — priced between ¥30,000 ($267) to ¥50,000 apiece. Poor signals within buildings also hinder the transmissions.

Mass e-mails sent to individual mobile phones are one alternative, but these fail to reach those without such phones — including many elderly people. Such limitations have made the pager frequency bandwidth of 280 megahertz more appealing.

Tokyo Telemessage Inc., the only firm in Japan providing such services, offers a portable terminal that can receive pager frequencies for around ¥20,000.

The firm said the equipment is nearly the size of the single receivers used for the wireless system during disasters. Wherever it is located, the terminal can receive signals, display text messages sent by local governments and convert such information to audio alerts.

As of late May, 21 municipalities in 12 prefectures have either introduced this service or plan to do so soon, according to Tokyo Telemessage.

Among them is the city of Yamato in Kanagawa Prefecture, near Tokyo, where audio messages transmitted via outdoor speakers using the wireless system often become inaudible in homes soundproofed to cope with noise from the U.S. Navy’s Atsugi air facility. The city introduced the pager service in 2015.

The pager frequency can “reach more easily even within buildings, and the cost is low,” a Yamato city official said, adding that the municipality hopes to use it in schools and social welfare facilities.

Tokyo Telemessage President Hidetoshi Seino said, “Inquiries and orders from local governments have increased since the Great East Japan Earthquake.”

Specialists in sales and service of equipment from these leading manufacturers, as well as other two-way radio and paging products:

	Motorola SOLUTIONS
	Motorola MOBILITY

Disaster-Proven Paging for Public Safety

Paging system designs in the United States typically use a voice radio-style infrastructure. These systems are primarily designed for outdoor mobile coverage with modest indoor coverage. Before Narrowbanding, coverage wasn’t good, but what they have now is not acceptable! The high power, high tower approach also makes the system vulnerable. If one base station fails, a large area loses their paging service immediately!

Almost every technology went from analog to digital except fire paging. So it’s time to think about digital paging! The Disaster-Proven Paging Solution (DiCal) from Swissphone offers improved coverage, higher reliability and flexibility beyond anything that traditional analog or digital paging systems can provide. 

Swissphone is the No. 1 supplier for digital paging solutions worldwide. The Swiss company has built paging networks for public safety organizations all over the world. Swissphone has more than 1 million pagers in the field running for years and years due to their renowned high quality.

DiCal is the digital paging system developed and manufactured by Swissphone. It is designed to meet the specific needs of public safety organizations. Fire and EMS rely on these types of networks to improve incident response time. DiCal systems are designed and engineered to provide maximum indoor paging coverage across an entire county. In a disaster situation, when one or several connections in a simulcast solution are disrupted or interrupted, the radio network automatically switches to fall back operating mode. Full functionality is preserved at all times. This new system is the next level of what we know as “Simulcast Paging” here in the U.S.

Swissphone offers high-quality pagers, very robust and waterproof. Swissphone offers the best sensitivity in the industry, and battery autonomy of up to three months. First responder may choose between a smart s.QUAD pager, which is able to connect with a smartphone and the Hurricane DUO pager, the only digital pager who offers text-to-voice functionality.

Bluetooth technology makes it possible to connect the s.QUAD with a compatible smartphone, and ultimately with various s.ONE software solutions from Swissphone. Thanks to Bluetooth pairing, the s.QUAD combines the reliability of an independent paging system with the benefits of commercial cellular network. Dispatched team members can respond back to the call, directly from the pager. The alert message is sent to the pager via paging and cellular at the same time. This hybrid solution makes the alert faster and more secure. Paging ensures alerting even if the commercial network fails or is overloaded.

Swissphone sets new standards in paging:

Paging Network

• It’s much faster to send individual and stacked pages digitally than with analog voice.
• If you want better indoor coverage, you put sites closer together at lower heights.
• A self-healing system that also remains reliable in various disaster situations.
• Place base station where you need them, without the usage of an expensive backhaul network.
• Protect victim confidentiality and prevent unauthorized use of public safety communications, with integrated encryption service.

Pager

• Reliable message reception, thanks to the best sensitivity in the industry.
• Ruggedized and waterproof, IP67 and 6 1/2-feet drop test-certified products.
• Battery autonomy of up to three months, with a standard AA battery.
• Bluetooth enables the new s.QUAD pager to respond back to the dispatch center or fire chief.

Dispatching:

• Two-way CAD interfaces will make dispatching much easier.
• The new s.ONE solution enables the dispatcher or fire chiefs to view the availability of relief forces.
• A graphical screen shows how many of the dispatched team members have responded to the call.

Swissphone provides a proven solution at an affordable cost. Do you want to learn more?
Visit: www.swissphone.com or call 800-596-1914.

Important Notice

June 22, 2017

Dear Fellow Paging System Owners, Operators, Managers, and Friends,

If someone would have told me back in 1982 when I was fresh out of technician school, and hired by Quintron as a Final Test Technician — that I would be working to sell their equipment until 2017 — I would have thought, “who is Quintron?” Well, I found out and have not been disappointed.

I have worked, in one aspect or another, in the paging industry for a total of 35 years. First I was hired as a technician at Quintron, then I moved into the training department and finally into the sales department, as an assistant, then as a sales representative. I have gotten to meet and work with some great people along the way. Many of them have retired a long time ago and many are still working in the business.

This equipment reselling business was started in response to a program Glenayre ran 18 years ago. They took a trade-in of some Motorola equipment to offset the cost of new Glenayre equipment. Instead of scrapping it, they elected to have my partner and me (at the time, Bill McManus) refurbish it and then sell it. The program ended after a few years but we continued to purchase as much as we could to supply parts and used equipment worldwide.

My reason for this letter is to tell you that I have decided to close the business and pursue some other interests outside of paging. But I still have quite a bit of equipment left that I need to move, and all of it is priced at “garage sale” prices. So, if anyone needs something on my list please contact me. I prefer to see it go to someone who can use it rather than the alternative.

I Thank all my customers and friends for the success of this business, and will miss working with you all. My scheduled date to close up is July 31st.

Thank you.

Rick McMichael
Preferred Wireless, Inc.
rickm@preferredwireless.com
(314) 575-8425

Rick McMichael, President

Skydata equipment

Repair Center

Warehouse

Tech work bench

Lots of inventory

Nucleus 900 MHz C-NET Equipment

PURC 5000 Parts

New indoor cabinets

Receivers, receivers, receivers & more

Lots of Nucleus 900 MHz Transmitters

Dummy loads and watt meters

Glenayre Midband & UHF receivers

900 MHz DSP Exciters

GLT 8500/8600 PAs

Skydata equipment

About Us:

Preferred Wireless, Inc. is a Missouri corporation in good standing since 1995. Personally I have been in the wireless industry since 1982. Originally working at Quintron and then with regional and national paging carriers until I made the leap into entrepreneurship in 1995. We began as a pager repair facility but quickly grew to a paging provider and equipment reseller.

Friday, June 30, 2017	Volume 5 | Issue 137

FCC Updates RF Device Authorization Rules

Manufacturers of RF devices like cell phones or TV receivers that are imported, marketed or operated within the U.S., will cheer after the FCC Thursday voted to modernize authorization requirements. Specifically, the change will allow labeling information to be provided to the consumer via electronic displays.

This means those who make devices with such displays no longer need to stamp or label the case of every single device for FCC certification. The change is expected to save manufacturers “a measurable reduction in costs,” according to the agency. Makers of devices without digital displays would still need to etch or affix a permanent label on each product.

The Commission also eliminated the requirement to file with U.S. Customs and Border Protection (CBP) the FCC Form 740 — the FCC’s unique import declaration for RF devices brought into the United States. A spike in imports has made this filing requirement “unwieldy” for the FCC; the CBP’s updated database and increasing availability of product information on the internet have reduced the need for the form.

The Commission is also combining two separate self-approval procedures into one, which will help reduce confusion as to which process applies to any given product. The new process, called the Suppliers Declaration of Conformity, will enable manufacturers to more efficiently bring products to market yet also ensure compliance with the equipment authorization program.

FirstNet Progress Under Senate Microscope

U.S. Sen. Roger Wicker (R-MS), chairman of the Subcommittee on Communications, Technology, Innovation, and the Internet, will convene a hearing titled “An Update on FirstNet” next Thursday, July 20. The subcommittee will examine FirstNet and AT&T’s progress to date and the anticipated timeline to build, operate, and maintain an interoperable nationwide public safety broadband network. Witnesses for the 10 a.m. hearing include: FirstNet CEO Michael Poth, AT&T SVP Chris Sambar, GAO Physical Issues Director Mark Goldstein, University of Mississippi Medical Center Assistant Professor Dr. Damon Darsey and Virginia Deputy Secretary of Public Safety and Homeland Security Curtis Brown.

Wireless Communication Solutions

USB Paging Encoder

• Single channel up to eight zones
• Connects to Linux computer via USB
• Programmable timeouts and batch sizes
• Supports 2-tone, 5/6-tone, POCSAG 512/1200/2400, GOLAY
• Supports Tone Only, Voice, Numeric, and Alphanumeric
• PURC or direct connect
• Pictured version mounts in 5.25" drive bay
• Other mounting options available
• Available as a daughter board for our embedded Internet Paging Terminal (IPT)

Paging Data Receiver (PDR)

• Frequency agile—only one receiver to stock
• USB or RS-232 interface
• Two contact closures
• End-user programmable w/o requiring special hardware
• 16 capcodes
• POCSAG
• Eight contact closure version also available
• Product customization available

Other products

Please see our web site for other products including Internet Messaging Gateways, Unified Messaging Servers, test equipment, and Paging Terminals.

Contact

Hark Technologies 717 Old Trolley Rd Ste 6 #163 Summerville, SC 29485

Tel: 843-821-6888

Fax: 843-821-6894

E-mail: sales@harktech.com CLICK

Web: http://www.harktech.com CLICK

A Problem

The Motorola Nucleus II Paging Base Station is a great paging transmitter. The Nucleus I, however, had some problems.

One of the best features of this product was its modular construction. Most of the Nucleus' component parts were in plug-in modules that were field replaceable making maintenance much easier.

One issue was (and still is) that two of the modules had to always be kept together. They are called the “matched pair.”

Motorola used some tricks to keep people in the field from trying to match unmatched pairs, and force them to send SCM and Exciter modules back to the factory for calibrating them with precision laboratory equipment.

The serial numbers have to match in the Nucleus programing software or you can't transmit [in simulcast mode] . Specifically the 4-level alignment ID parameter contained in the SCM has to match the Exciter ID parameter.

Even if someone could modify the programing software to “fudge” these parameters, that would not let them use unmatched modules effectively without recalibrating them to exact factory specifications.

So now that there is no longer a Motorola factory laboratory to send them to, what do we do?

I hope someone can help us resolve this serious problem for users of the Nucleus paging transmitter.

Please let me know if you can help. [click here]

[Thanks to Tom Harger Chief Engineer at Contact Wireless for the correction above in red.]

Selected portions [sometimes more — sometimes less] of the BloostonLaw Telecom Update and/or the BloostonLaw Private Users Update — newsletters from the Law Offices of Blooston, Mordkofsky, Dickens, Duffy & Prendergast, LLP — are reproduced in this section of The Wireless Messaging News with the firm’s permission. Contact information is included at the end of the newsletter.

REMINDER: Reply Comments on the FCC’s Broadband Infrastructure Proceedings Due July 17

The reply comment cycle for the FCC’s broadband infrastructure proceedings is approaching. For wireline deployment the FCC is seeking comment on (i) pole attachment rules; (ii) copper retirement rules; and (iii) Section 214 discontinuance requirements. For wireless deployment, the FCC is seeking comment on (i) streamlining state and local review; (ii) reexamining National Environmental Policy Act and National Historic Preservation Act review; and (iii) prohibiting State or local regulations that have the effect of prohibiting the provision of telecommunications.

Any clients that have concerns about these matters should take advantage of this opportunity by participating in comments. Please contact the firm ASAP if you have any questions or concerns that can be addressed in such comments.

BloostonLaw Contacts: Ben Dickens, Gerry Duffy, and Sal Taillefer.

Headlines

FCC Issues Guidance on Applicability of Privacy Rules

On June 29, the FCC issued an Order clarifying that the privacy rules for telecommunications carriers in existence prior to the 2016 Privacy Order are once again in effect, pursuant to the resolution of disapproval under the Congressional Review Act.

As previously reported in the BloostonLaw Telecom Update, Tom Wheeler’s FCC adopted the 2016 Privacy Order (also known as the Broadband Privacy Order) at the end of October 2016. In addition to extending privacy protection requirements to broadband Internet access service (BIAS) providers, the 2016 Privacy Order also modified existing telecom rules concerning the treatment of customer proprietary network information (CPNI) under section 222 of the Communications Act. For example, the FCC established a framework of customer consent to use and share customers’ personal information that is “calibrated to the sensitivity of the information” — i.e., affirmative “opt-in” consent for “sensitive information,” such as precise geo-location, financial information, health information, children’s information, social security numbers, web browsing history, app usage history and the content of communications, and an opt-out option for use of non-sensitive information.

Earlier this year, Congress repealed the 2016 Broadband Privacy Act through the use of the Congressional Review Act (CRA). The CRA allows Congress to eliminate agency rules with a simple majority vote. Prior to 2017, the CRA had only been successfully invoked once to overturn a rule (in 2001); in January 2017, however, the newest Congress began passing a series of disapproval resolutions to overturn a variety of rules issued under the Obama administration, and by the end of February, three of these had already been signed into law by President Trump. Because of the shortness of legislative sessions during the 114th Congress, the 115th Congress was able to target rules passed by the Obama administration (at least) as far back as May 2016, as Congress has a window of time lasting 60 legislative days (i.e., days that the U.S. Congress is actually in session, rather than calendar days) to disapprove of any given rule.’

There has been some uncertainty in the industry as to what privacy rules are in effect in the wake of the Congressional action to undo them. Through this Order, the FCC has clarified that the status quo ante is restored.

BloostonLaw Contacts: Ben Dickens, Gerry Duffy, and Sal Taillefer.

President Trump Announces Intent to Nominate Brendan Carr to FCC

On June 28, multiple news outlets reported that President Trump said he will nominate Brendan Carr, currently the Federal Communications Commission’s general counsel, as a Republican commissioner at the agency. According to The Wall Street Journal, “[t]he choice is a victory for the FCC’s new Republican chairman, Ajit Pai. Mr. Carr was an aide to Mr. Pai before becoming the agency’s general counsel.”

In a statement, Chairman Pai said of the nomination, “I congratulate Brendan Carr on the President’s announcement that he will be nominated to serve as an FCC Commissioner. Brendan has a distinguished record of public service, having worked at the agency for over five years, including most recently as the FCC’s General Counsel. In particular, Brendan’s expertise on wireless policy and public safety will be a tremendous asset to the Commission. I look forward to working with him in his new role and wish him all the best during the confirmation process.”

Carr, as well as the recently-renominated Jessica Rosenworcel, will be need to be confirmed by the Senate before taking their seats at the FCC.

BloostonLaw Contacts: Ben Dickens, Mary Sisak, and Sal Taillefer.

FCC Seeks to Refresh Record on Toll Free Calling Access Charges

On June 29, the FCC”s Wireline Competition Bureau issued a Public Notice inviting interested parties to refresh the record on issues raised in the 2011 USF/ICC Transformation FNPRM with respect to access charges for 8YY (toll free) calls. Comments are due July 31, and reply comments are due August 15.

The Public Notice was prompted by the submission of an ex parte letter by the Ad Hoc Telecommunications Users Committee (Ad Hoc) “urging the Commission to ‘restore the historic treatment of 8YY traffic for access charge purposes, pursuant to which carriers are required to apply the per minute charges for terminating traffic to the originating or ‘open’ end of 8YY calls.’” According to the Public Notice, Ad Hoc also notes “AT&T’s recent observation that arbitrage and access stimulation schemes are increasingly shifting to 8YY service.” Issues upon which the FCC seeks comment include whether the FCC should adopt a distinct resolution for 8YY originating traffic and how such a resolution would be implemented.

BloostonLaw Contacts: Ben Dickens and Gerry Duffy.

Comment Deadline Established for Code BLU NPRM

On June 30, the FCC’s Public Safety and Homeland Security Bureau issued a Public Notice announcing that the Notice of Proposed Rulemaking (NPRM) that proposed to amend the Emergency Alert System (EAS) rules to adopt a new EAS event code that will allow the transmission of “Blue Alerts” to the public over the EAS was published in the Federal Register. Accordingly, comments are due on or before July 31, and reply comments are due on August 29.

As we reported in a previous edition of the BloostonLaw Telecom Update, the Code BLU NPRM — which was adopted at the FCC’s June Open Meeting — proposes to revise the FCC’s rules governing the EAS to incorporate a new event code, “BLU”, for Blue Alerts. Adding this event code would allow alert originators to issue an alert whenever a law enforcement officer is injured or killed, missing in connection with their official duties, or if there is an imminent and credible threat to cause death or serious injury to law enforcement officers.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

Law & Regulation

1300 – 1350 MHz Band of Spectrum May Be Freed Up for Commercial Use

A bipartisan pair of U.S. Senators secured language in an FAA reauthorization bill approved by the Senate Commerce Committee last week that could eventually make additional low-band spectrum available for commercial use.

Sens. Cory Gardner (R-CO) and Maggie Hassan (D-NH) co-sponsored an amendment to the FAA reauthorization legislation which provides “the sense of Congress” that the agency “should continue its assessment of the feasibility of making the 1300-1350 megahertz band of electromagnetic spectrum available for non-Federal use.”

The FAA, Department of Defense (DOD) and Department of Homeland Security (DHS) currently use this spectrum sub-band for a number of long-range radar systems. A November 2016 report by the NTIA found that heavy and diverse usage of these channels gave them limited potential for government-commercial sharing, but suggested it might be feasible to free the band for commercial use by combining various single-function surveillance systems into a single common government network that would operate on federal spectrum in the 2700-3100 MHz frequency range.

According to the NTIA report, one of several options for future feasibility studies to assess the potential accommodation of wireless broadband in the 1300-1390 MHz band would include making contiguous or noncontiguous blocks of cleared or partially cleared spectrum in the 1300-1350 MHz sub-band available for wireless broadband if the FAA/DOD/DHS long-range radars can be migrated from the 1300-1390 MHz band.

The amendment offered by Sens. Gardner and Hassan would make the FAA “identify additional low-band spectrum for commercial use,” CTIA Senior Vice President Kelly Cole said in a statement. “Every 10 MHz of spectrum made available for wireless service creates over 1.6 million jobs and generates $24.3 billion in GDP growth.”

In 2010, President Obama tasked NTIA to work with the FCC to make 500 megahertz of additional federal and non-federal spectrum available for wireless broadband within 10 years while also ensuring that agencies could meet their spectrum-driven missions.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

House Appropriations Committee Releases Agriculture Bill, Includes $6.9 Billion for Rural Telecom

On June 27, the U.S. House of Representatives Committee on Appropriations released the fiscal year 2018 Agriculture Appropriations bill, which will fund rural electrification and telecommunications, as well as various agricultural and food programs and services, including food and medical product safety, animal and plant health programs, rural farm services, agricultural trade, financial marketplace oversight, and nutrition programs. The legislation provides $6.94 billion for rural electric and telephone infrastructure loans, the same level as fiscal year 2017.

“This Appropriations bill reflects the will of our Members,” said Committee Chairman Rodney Frelinghuysen (RNJ). “I invited colleagues last week to let me know their priorities for the Agriculture, FDA and other titles in the bill. I am grateful that a number of people came forward to let us help with issues important to farmers, ranchers and the people who make rural America the heartland of America. I am pleased to say that we were able to accommodate these Member requests within the bill and look forward to moving a conservative bill through the legislative process.”

BloostonLaw Contacts: Ben Dickens, Gerry Duffy, and John Prendergast.

Industry

Chairman Pai Appoints New Bureau Chief, Chief Economist

On June 28, Chairman Ajit Pai announced that the FCC has chosen Wayne Leighton as chief of the FCC’s Office of Strategic Planning and Policy Analysis, the current acting chief. According to the Press Release, the Office of Strategic Planning and Policy Analysis “helps the Commission develop strategic plans, identify the agency’s policy objectives, and provide analysis and advice regarding complex, novel communications issues.”

Prior to serving as acting chief, Mr. Leighton served as a senior economist in the Wireless Telecommunications Bureau and as wireless advisor to then-FCC Commissioner Deborah Taylor Tate. Prior to his FCC service, Mr. Leighton worked for an economic consulting firm, was senior economist with the U.S. Senate Committee on Banking, Housing, and Urban Affairs, and has been a professor of economics at Universidad Francisco Marroquín in Guatemala. He earned a doctorate in economics from George Mason University and undergraduate degrees in business and economics from Texas A&M University.

On July 5, Chairman Pai announced the appointment of Jerry Ellig as chief economist for the FCC. Dr. Ellig currently serves as a senior research fellow at the Mercatus Center at George Mason University. According to the Press Release, the FCC chief economist advises the Chairman, Commissioners, and Bureaus and Offices on economic issues. Additionally, in April, Chairman Pai announced his intention to create an Office of Economics and Data to provide economic analysis for rulemakings, transactions, and auctions; manage the commission’s data resources; and conduct longer-term research on ways to improve the commission’s policies. The chief economist will assist the agency in standing up this new office.

Dr. Ellig has worked as a senior research fellow at the Mercatus Center at George Mason University since 1996. He previously served in the federal government as deputy director of the Office of Policy Planning at the Federal Trade Commission (2001-03) and as a senior economist at the Joint Economic Committee of the U.S. Congress (1995-96). He has also served as an associate professor of economics and adjunct professor of law at George Mason University. He holds a Ph.D. and M.A. in economics from George Mason University in Fairfax, VA, and a B.A. in economics from Xavier University in Cincinnati, OH.

Deadlines

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, 2013. Incumbent carriers filing on a quarterly basis must also file on September 30 (for lines served as of March 31, 2014); December 30 (for lines served as of June 30, 2014), and March 31, 2015, for lines served as of September 30, 2014).

BloostonLaw Contacts: Ben Dickens and Gerry Duffy.

JULY 31: CARRIER IDENTIFICATION CODE (CIC) REPORTS. Carrier Identification Code (CIC) Reports must be filed by the last business day of July (this year, July 31). These reports are required of all carriers who have been assigned a CIC code by NANPA. Failure to file could result in an effort by NANPA to reclaim it, although according to the Guidelines this process is initiated with a letter from NANPA regarding the apparent non-use of the CIC code. The assignee can then respond with an explanation. (Guidelines Section 6.2). The CIC Reporting Requirement is included in the CIC Assignment Guidelines, produced by ATIS. According to section 1.4 of that document: At the direction of the NANPA, the access providers and the entities who are assigned CICs will be requested to provide access and usage information to the NANPA, on a semi-annual basis to ensure effective management of the CIC resource. (Holders of codes may respond to the request at their own election). Access provider and entity reports shall be submitted to NANPA no later than January 31 for the period ending December 31, and no later than July 31 for the period ending June 30. It is also referenced in the NANPA Technical Requirements Document, which states at 7.18.6: CIC holders shall provide a usage report to the NANPA per the industry CIC guidelines … The NAS shall be capable of accepting CIC usage reports per guideline requirements on January 31 for the period ending December 31 and no later than July 31 for the period ending June 30. These reports may also be mailed and accepted by the NANPA in paper form. Finally, according to the NANPA website, if no local exchange carrier reports access or usage for a given CIC, NANPA is obliged to reclaim it. The semi-annual utilization and access reporting mechanism is described at length in the guidelines.

BloostonLaw contacts: Ben Dickens and Gerry Duffy.

AUGUST 1: LIVE 911 CALL DATA REPORTS FOR NON-NATIONWIDE CMRS PROVIDERS. Non- Nationwide CMRS Providers that do not provide coverage in any of the Test Cities must collect and report aggregate live 911 call data based on the largest county within its footprint to APCO, NENA, and NASNA on the location technologies used for live 911 calls in those areas. Carriers should obtain spreadsheets with their company’s compliance data from their E911 service provider (e.g., Intrado / West). Our law firm is available to review and/or assist in preparing these reports. This is a recurring report due every six months — on first business day of second month after the six month period for which data is reported.

BloostonLaw Contact: Cary Mitchell.

AUGUST 1: 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. 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.

BloostonLaw Contacts: Ben Dickens and Gerry Duffy.

AUGUST 1: 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 1. 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. 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 and Gerry Duffy.

AUGUST 3: E911 INDOOR LOCATION ACCURACY FOR CMRS - INITIAL IMPLEMENTATION PLAN AND FIRST PROGRESS REPORT. All CMRS service providers must prepare and submit to the FCC an Initial Implementation Plan which describes their company’s plans for meeting the FCC’s improved indoor location accuracy requirements, as well as a related First Progress Report which describes their efforts to date toward meeting the plan. The FCC has not specified a particular format for these filings, so we are preparing a template that will combine both into a single report. Please contact us if you want us to assist your company in preparing either or both of these filings.

BloostonLaw Contact: Cary Mitchell.

AUGUST 29: COPYRIGHT STATEMENT OF ACCOUNTS. The Copyright Statement of Accounts form plus royalty payment for the first half of calendar year 2014 is due to be filed August 29 at the Library of Congress’ Copyright Office by cable TV service providers.

BloostonLaw Contact: Gerry Duffy.

SEPTEMBER 1: FCC FORM 477, LOCAL COMPETITION AND BROADBAND REPORTING FORM. Three types of entities must file this form. (1) Facilities-based Providers of Broadband Connections to End User Locations: Entities that are facilities-based providers of broadband connections – which are wired “lines” or wireless “channels” that enable the end user to receive information from and/or send information to the Internet at information transfer rates exceeding 200 kbps in at least one direction — must complete and file the applicable portions of this form for each state in which the entity provides one or more such connections to end user locations. For the purposes of Form 477, an entity is a “facilities-based” provider of broadband connections to end user locations if it owns the portion of the physical facility that terminates at the end user location, if it obtains unbundled network elements (UNEs), special access lines, or other leased facilities that terminate at the end user location and provisions/equips them as broadband, or if it provisions/equips a broadband wireless channel to the end user location over licensed or unlicensed spectrum. Such entities include incumbent and competitive local exchange carriers (LECs), cable system operators, fixed wireless service providers (including “wireless ISPs”), terrestrial and satellite mobile wireless service providers, MMDS providers, electric utilities, municipalities, and other entities. (Such entities do not include equipment suppliers unless the equipment supplier uses the equipment to provision a broadband connection that it offers to the public for sale. Such entities also do not include providers of fixed wireless services (e.g., “Wi-Fi” and other wireless ethernet, or wireless local area network, applications) that only enable local distribution and sharing of a premises broadband facility.) (2) Providers of Wired or Fixed Wireless Local Telephone Services: Incumbent and competitive LECs must complete and file the applicable portions of the form for each state in which they provide local exchange service to one or more end user customers (which may include “dial-up” ISPs). (3) Providers of Interconnected Voice over Internet Protocol (VoIP) Service: Interconnected VoIP service is a service that enables real-time, two-way voice communications; requires a broadband connection from the user’s location; requires Internet-protocol compatible customer premises equipment; and permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network. Interconnected VoIP providers must complete and file the applicable portions of the form for each state in which they provide interconnected VoIP service to one or more subscribers, with the state determined for reporting purposes by the location of the subscriber’s broadband connection or the subscriber’s “Registered Location” as of the data-collection date. “Registered Location” is the most recent information obtained by an interconnected VoIP service provider that identifies the physical location of an end user. (4) Providers of Mobile Telephony Services: Facilities-based providers of mobile telephony services must complete and file the applicable portions of this form for each state in which they serve one or more mobile telephony subscribers. A mobile telephony service is a real-time, two-way switched voice service that is interconnected with the public switched network using an in-network switching facility that enables the provider to reuse frequencies and accomplish seamless handoff of subscriber calls. A mobile telephony service provider is considered “facilities-based” if it serves a subscriber using spectrum for which the entity holds a license that it manages, or for which it has obtained the right to use via lease or other arrangement with a Band Manager.

BloostonLaw contacts: Ben Dickens and Gerry Duffy.

SEPTEMBER 30: FCC FORM 396-C, MVPD EEO PROGRAM REPORTING FORM. Each year on September 30, multi-channel video program distributors (“MVPDs”) must file with the Commission an FCC Form 396-C, Multi-Channel Video Programming Distributor EEO Program Annual Report, for employment units with six or more full-time employees. Users must access the FCC’s electronic filing system via the Internet in order to submit the form; it will not be accepted if filed on paper unless accompanied by an appropriate request for waiver of the electronic filing requirement. Certain MVPDs also will be required to complete portions of the Supplemental Investigation Sheet (“SIS”) located at the end of the Form. These MVPDs are specifically identified in a Public Notice each year by the FCC.

BloostonLaw Contacts: Gerry Duffy and Sal Taillefer.

Calendar At-A-Glance

July
Jul. 6 – Comments are due on BDS for Model Based RoR Carrier Petition for Rulemaking.
Jul. 7 – Comments are due on CAF Phase II Census Block List.
Jul. 7 – Reply comments are due on FY2017 Regulatory Fee NPRM.
Jul. 10 – Comments are due on Local Service Rate Floor NPRM.
Jul. 10 – Deadline for MVPDs to Pass Through Emergency Information.
Jul. 11 – Reply comments are due on VRS User Equipment Profile FNPRM.
Jul. 17 – Reply comments are due on Wireless Broadband Infrastructure proceeding.
Jul. 17 – Reply comments are due on Wireline Broadband Infrastructure proceeding.
Jul. 17 – Comments are due on Broadband Title I Reclassification NPRM.
Jul. 21 – Reply comments are due on BDS for Model Based RoR Carrier Petition for Rulemaking.
Jul. 24 – Reply comments are due on Local Service Rate Floor NPRM.
Jul. 31 – FCC Form 507 (Universal Service Quarterly Line Count Update) is due.
Jul. 31 – Carrier Identification Code (CIC) Report is due.
Jul. 31 – International Traffic Data Report is due.
Jul. 31 – Deadline for comments refreshing the record on Toll Free Calling Access Charges.
Jul. 31 – Reply comments are due on Robocall Blocking proceeding.

August
Aug. 1 – FCC Form 502 due (North American Numbering Plan Utilization and Forecast Report).
Aug. 1 – FCC Form 499-Q (Quarterly Telecommunications Reporting Worksheet) is due.
Aug. 1 - Live 911 Call Data Reports for Non-Nationwide Providers due.
Aug. 3 – E911 Indoor Location Accuracy Initial implementation plan / first progress reports due.
Aug. 7 – Deadline to file for 3.65-3.7 GHz Grandfathered Protection Zone.
Aug. 15 – Deadline for reply comments refreshing the record on Toll Free Calling Access Charges.
Aug. 16 – Reply comments are due on Broadband Title I Reclassification NPRM.
Aug. 29 – Copyright Statement of Accounts is due.

September
Sep. 1 – FCC Form 477 due (Local Competition and Broadband Report).
Sep. 30 – FCC Form 396-C (MVPD EEO Program Annual Report).

Chairman Pai Issues Ultimatum to USAC, Seeks De-Enrollment and Recapture for Offending Accounts

On July 11, Chairman Ajit Pai sent a detailed letter to USAC demanding action be taken to curb waste, fraud, and abuse identified in the Lifeline program by a recent report by the Government Accountability Office. Although directed toward USAC, it is likely that some of the leg-work will fall on ETCs that may have erroneous records, including de-enrollment and re-verification. The Chairman has also instructed USAC to recapture support amounts provided for offending accounts.

See the full article below for more information.

BloostonLaw Contacts: Ben Dickens, Mary Sisak, and Sal Taillefer.

Headlines

FCC Eliminates Certain Form 481 Filing Requirements

On July 7, the FCC issued a Report and Order eliminating several reporting requirements that it deems to be “either duplicative of other reporting requirements or are simply no longer necessary.” Specifically, the FCC held that:

• The rule requiring that ETCs’ annual reports include detailed information about any outages affecting voice service for at least 30 minutes that they have experienced in the prior calendar year was eliminated because the Commission’s Network Outage Reporting System (NORS) already collects detailed outage information, and does so in a more timely fashion than the FCC Form 481.
• The rule requirement that ETCs report the number of service requests they receive but do not fulfill was eliminated because the FCC found that rule as written is not appropriately tailored to further the goal. Specifically, the FCC held that, “absent uniform and clear standards for how individual carriers evaluate such requests, the data reported cannot support any meaningful evaluation.”
• The obligation that ETCs annually report the number of complaints per 1,000 subscribers for voice and broadband services was eliminated because “the high-level complaint data currently collected on Form 481 is not as useful as the detailed data already collected by CGB through the complaint process, in part because the Form 481 data do not currently contain information about individual complaints.”
• The requirement to report annually information regarding the pricing of their voice and broadband service offerings was eliminated because the FCC found that it has “not made sufficient use of this pricing data to support its continued collection. [The FCC] primarily rel[ies] on the urban rate survey to develop annually the reasonable comparability benchmarks for both voice and broadband services, and annual certifications from providers that their rates do not exceed those benchmarks.”
• The requirement that an ETC certify its compliance with applicable service quality standards and consumer protection rules was eliminated because ETCs already have an independent obligation to comply with all applicable service quality standards and consumer protection rules. That obligation exists, and the FCC or USAC may enforce it, regardless of whether the ETC certifies.
• The requirement of filing duplicate copies of Form 481 with the FCC and with states, U.S. Territories, and/or Tribal governments was eliminated because in the Rate-of-Return Reform Order, the FCC directed USAC to “timely publish through electronic means all non-confidential high-cost data in open, standardized, electronic formats, consistent with the principles of the Office of Management and Budget’s Open Data Policy,” and directed WCB “to work with USAC to put appropriate protections in place for ETCs to seek confidential treatment of a limited subset of the information,” making the duplicate filings unnecessary.

These eliminations are scheduled to go into effect immediately upon approval by the Office of Management and Budget. Given that the Report and Order was adopted just days after this year’s Form 481 filing was due, it’s likely that these changes will be in effect for next year’s filing. However, it is important to note that the elimination of duplicate filings is contingent upon USAC’s successful implementation of the electronic database.

BloostonLaw Contacts: Gerry Duffy, Mary Sisak, and Sal Taillefer.

FCC to Consider Expanded Use of Mid-Band Spectrum for Super-Fast Fixed Wireless Services

FCC staff is working on a Notice of Inquiry (NOI) that could lead to expanded use of certain mid-band spectrum for fixed wireless broadband services, which proponents believe could enable multiple providers to offer competitive gigabit or near-gigabit service.

FCC Commissioners are likely to vote August 3 on an NOI concerning additional uses for spectrum in the 3.7 to 4.2 GHz and 6 GHz bands, which are currently used for the Fixed Satellite Service (FSS). The item grew out of a Petition for Rulemaking filed last October by the Fixed Wireless Communications Coalition (FWCC), seeking modified coordination procedures in bands shared between terrestrial and the Fixed Satellite Service. FWCC membership consists of providers, users, and manufacturers of terrestrial Fixed Service (FS) radio communications services and equipment.

Because FCC rules permit FSS earth stations to coordinate across an entire frequency band, and over the entire geostationary arc – regardless of how little spectrum the earth stations plan to use - large amounts of spectrum shared by the FS and FSS can go needlessly unused.
Earlier this year, both Google Fiber and Nokia filed comments in support of the FWCC Petition urging the Commission to consider more broadly whether rule changes can open additional opportunities for service in the 3.7 GHz to 4.2 GHz spectrum band.

“The current Part 101 regulations for these frequencies are optimized for high-power, long-haul microwave transmissions that are of diminished importance in the era of fiber-optic communications,” wrote Google. “Several relatively simple changes—such as modifying power limits, specifically authorizing point-to-multipoint connections in the band, and updating antenna requirements—would enable use of the 3.7-4.2 GHz band for short-range, superfast broadband connections, as well.”

Supporting comments by Nokia describe new uses for the 3.7-4.2 GHz band that are currently being investigated. “One such fixed wireless application that Nokia is testing in real-world environments with its partners is for extreme broadband in which traditionally wired broadband access to residential and commercial buildings is, instead, provided wirelessly. Fixed wireless service can become an alternative to fiber to the home to speed up deployments for last-mile broadband delivery.”

More recently, the Broadband Access Coalition, a group of fixed wireless technology companies and non-profit advocacy groups, filed a Petition for Rulemaking urging the Commission to amend and modernize Parts 25 and 101 of the rules “to authorize and facilitate a new, licensed fixed wireless point-to-multipoint (“P2MP”) high-speed broadband service on a shared basis in the underutilized 3700 – 4200 MHz band.

A July 10 blog post by Commissioner Mike O’Rielly describes the opportunity as “A Mid-Band Spectrum Win in the Making.” O'Rielly said the proposal would free up a total of 1700 megahertz of spectrum, 500 megahertz for licensed and up to 1.2 gigahertz for unlicensed purposes. Under the coalition proposal, existing licensees would either be protected or otherwise accommodated. For example, the fixed service users in the 6 GHz band would be protected by unlicensed users and could expand their usage.

“When presented with a viable proposal that would free spectrum for licensed and unlicensed purposes while protecting or accommodating incumbent licensees, the Commission should grab it with both hands and rejoice,” wrote O’Rielly. “That exact scenario presents itself in the 3.7 to 4.2 GHz and 6 GHz bands.”

Next generation (i.e., 5G) wireless networks will require high, mid and low band spectrum. Our clients that are interested in the possible use of fixed wireless for last mile broadband access, and/or the possibility that competitors may enter the market these services, should stay apprised of the NOI and any subsequent rulemaking that may come as soon as next year.

BloostonLaw Contacts: Cary Mitchell and John Prendergast.

Chairman Pai Orders Immediate Action on Lifeline Waste, Fraud and Abuse

On July 11, FCC Chairman Ajit Pai wrote a letter to USAC acting CEO and general counsel Vickie Robinson calling for “immediate action.” The Chairman’s letter comes in the wake of a recent report by the Government Accountability Office (GAO) indicating extensive waste, fraud, and abuse in the Lifeline fund. While Chairman Pai is primarily directing USAC to take action, it is likely that eligible telecommunications carriers (ETCs) will be required to get involved to the extent USAC determines some fraud has occurred. At a minimum, ETCs should expect to have to de-enroll offending subscriptions and be prepared for USAC to recapture support funding provided for such subscriptions.

Specifically, the Chairman asked USAC to implement the following safeguards as soon as possible:

Ineligible Subscribers. USAC must identify the top ten ETCs (on a holding company basis) with the highest number of potentially ineligible subscribers according to GAO's study and audit each of these ETCs to determine whether they are properly verifying the eligibility of their subscribers. Every month over the course of the next year, USAC must review a statistically valid sample of subscribers enrolled or re-certified by each of these ten ETCs in the prior month to determine whether those subscribers are in fact eligible to participate in the Lifeline program, and require each ETC to de-enroll any subscribers whose eligibility cannot be verified. Further, USAC must require all ETCs with GAO-identified potentially ineligible subscribers to verify the eligibility of such subscribers and to de-enroll from the Lifeline program any subscribers whose eligibility the ETC cannot properly verify.

Oversubscribed Addresses. USAC must identify and review every address associated with 500 or more subscribers, and require all relevant ETCs to de-enroll any subscribers that cannot verify their residence at a location that could reasonably accommodate them as well as any subscribers that cannot confirm they are "independent economic households" (within the meaning of the FCC's rules) from other subscribers at that address. Every quarter going forward, beginning with the third quarter of 2017 (July-September), USAC must review a sample of addresses associated with 25 or more subscribers and require all relevant ETCs to de-enroll any subscribers that cannot verify their residence at a location that could reasonably accommodate them as well as any subscribers that cannot confirm they are independent economic households from other subscribers at that address. USAC must recapture any improper payments associated with such de-enrolled subscribers from the relevant ETC(s).

Phantom Subscribers. USAC must develop a process to identify ETCs with material discrepancies that cannot be adequately explained between the NLAD and claimed support on their Form 497 submissions. Every quarter going forward, USAC must direct ETCs with discrepancies that cannot be adequately explained to correct their NLAD listings and Form 497 submissions as appropriate. As part of USAC's audits of ETCs, USAC must check any discrepancies between the NLAD and the claimed support of the audited ETC, and must require such ETC to correct any material differences in their NLAD listings and Form 497 submissions as appropriate. USAC must recapture any improper payments associated with such de-enrolled subscribers from the relevant ETC(s).

Deceased Subscribers. USAC must require the relevant ETCs to immediately de-enroll the deceased subscribers identified by GAO and recover improper Lifeline payments associated with these subscribers. Every quarter going forward, USAC must check a sample of subscribers enrolled or re-certified during the previous quarter against the Social Security Master Death Index, and require the relevant ETCs to de-enroll any deceased individuals. USAC must also recapture any improper payments associated with such de-enrolled subscribers from the relevant ETC(s).

Exact Duplicates. USAC must require each sales agent to register with USAC, with sufficient information so that USAC can verify the agent's identity and determine the ETC(s) he or she works for. Each registered sales agent must receive a unique identifier that must be used for all such agent's interactions with the NLAD. USAC must adjust the NLAD to lock sales agents out of the system for a set period of time after too many invalid subscriber entry attempts. USAC must refer any substantial enrollment or recertification of ineligible subscribers by particular sales agents, as well as any program violations by sales agents, to the Commission's Office of lnspector General for evaluation as to whether civil or criminal action is appropriate and to the Enforcement Bureau for administrative action and remedies.

Chairman Pai has requested a report on USAC’s progress by August 8, making it look like a very busy July for the Administrator.

BloostonLaw Contacts: Gerry Duffy, Mary Sisak, and Sal Taillefer.

Senators Urge FCC To Prepare for Net Neutrality Comment “Deluge”

On July 10, Sen. Ron Wyden (D-Ore.), and Sen. Brian Schatz, (D-Hawaii), sent a letter to the FCC urging the agency to ensure its commenting system is prepared to withstand a cyberattack as well as “a surge of comments expected on July 12,” a day of action for supporters of net neutrality.

“The FCC must be able to accept all comments filed to ensure that all voices are heard,” the Senators wrote in a letter to FCC Chairman Ajit Pai. The Senators also emphasized the need for the FCC to prepare for the type of cyberattack that knocked the agency’s commenting system offline on May 7 and 8, and to provide for other ways to comment if an attack derails the online system again.

“In case the [online commenting system] is disabled through some new type of attack, it is critical that Americans be able to file a comment using other means,” the Senators wrote. “We urge you to undertake temporary measures to ensure a functioning system on and around the anticipated surge of legitimate comments.”

BloostonLaw Contacts: Ben Dickens and Sal Taillefer.

Law & Regulation

FCC Adopts Video Description Report and Order Ahead of Open Meeting

On July 12, the FCC issued a Press Release announcing that it adopted new video description rules that are designed to ensure the blind and visually impaired are able to have access to more video-described programming. Specifically, beginning July 2018, broadcasters and pay-TV providers carrying one of the top networks must provide 87.5 hours of described programming per calendar quarter, which averages out to roughly one hour per day of description on each included network. This is an increase of 75 percent over the 50 hours per quarter presently required. While the current 50 hour requirement must be provided during prime-time or children’s programming, the additional 37.5 hours per quarter being added by these new rules can be provided at any time of day between 6 a.m. and midnight. The networks currently covered by the rule are ABC, CBS, Fox, NBC, Disney Channel, History, TBS, TNT, and USA. However, the list of the top five non-broadcast networks will be updated in July 2018, so this is subject to change.

Video description is provided through the TV or set top box “secondary audio” feature, which some TV controls identify as “SAP” or “secondary audio program.” It allows people with limited vision to hear a description of on-screen activity while also following the dialogue, providing a more fulsome entertainment experience. In a statement, Chairman Pai said, “[t]his decision will allow Americans who rely on video description to have greater access to described programming.”

BloostonLaw Contacts: Ben Dickens, Gerry Duffy, and John Prendergast.

Senate to Hold Nomination Hearing for FCC Reappointments, Nomination

On July 19, U.S. Sen. John Thune (R-S.D.), chairman of the Senate Committee on Commerce, Science, and Transportation, will hold a hearing on the re-appointment of FCC Chairman Ajit Pai and former Commissioner Jessica Rosenworcel. The hearing will also cover the nomination of Brendan Carr to the FCC.

“This hearing will continue to advance our committee’s fulfillment of its constitutional charge to consider nominees appointed by the President for federal office,” said Thune. “The FCC has significant responsibilities over one of the most innovative sectors of our economy and I look forward to asking these qualified nominees about challenges to advancing the public interest.” The nominees’ questionnaires are available at www.commerce.senate.gov/nominations.

BloostonLaw Contacts: Ben Dickens and Gerry Duffy.

Industry

Microsoft Unveils Plan to Bridge Digital Divide in Rural Areas with TV White Space Broadband

On July 10, Microsoft announced its plans to eliminate the rural broadband gap by July 4, 2022, using TV White Spaces spectrum. According to a white paper published by Microsoft, the company’s “Rural Airband Initiative” will:

• Invest in partnerships with telecommunications companies with the goal of having at least 12 projects up and running in 12 states in the next 12 months. According to the white paper, Microsoft’s goal “is not to enter the telecommunications business ourselves or even to profit directly from these projects.” Rather, the company plans to invest in the upfront capital projects needed to expand broadband coverage, seek a revenue share from operators to recoup investment, and then use these revenue proceeds to invest in additional projects to expand coverage further.
• Invest in digital skills training through partnership with the National 4-H Council, as well as creating opportunities for Microsoft’s own employees to volunteer and get involved in projects.
• Stimulate investment by others through technology licensing. More specifically, the company plans to launch a new technology program to share its insights and experience with other companies, including providing royalty-free access to at least 39 patents and sample source code related to technology Microsoft technology that has been developed to better enable broadband connectivity through TV white spaces spectrum in rural areas.

Microsoft also called upon the FCC to help pave the way for its program. According to the white paper, three governmental measures are needed:

• The FCC must ensure that three channels below 700 MHz are available for wireless use on an unlicensed basis in every market in the country, with additional TV white spaces available in smaller markets and rural areas.
• Federal and state infrastructure investments should include targeted funds on a matching basis for the capital investments that will best expand coverage into rural areas that currently lack broadband access today.
• The FCC should accelerate its work to collect and report publicly on the state of broadband coverage in rural counties.

The twelve states Microsoft is targeting with its initial 12-states-in-12-months agenda are: Washington, North Dakota, South Dakota, Kansas, Arizona, Texas, Georgia, Virginia, New York, Maine, Wisconsin, and Michigan.

Deadlines

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, 2013. Incumbent carriers filing on a quarterly basis must also file on September 30 (for lines served as of March 31, 2014); December 30 (for lines served as of June 30, 2014), and March 31, 2015, for lines served as of September 30, 2014).

BloostonLaw Contacts: Ben Dickens and Gerry Duffy.

JULY 31: CARRIER IDENTIFICATION CODE (CIC) REPORTS. Carrier Identification Code (CIC) Reports must be filed by the last business day of July (this year, July 31). These reports are required of all carriers who have been assigned a CIC code by NANPA. Failure to file could result in an effort by NANPA to reclaim it, although according to the Guidelines this process is initiated with a letter from NANPA regarding the apparent non-use of the CIC code. The assignee can then respond with an explanation. (Guidelines Section 6.2). The CIC Reporting Requirement is included in the CIC Assignment Guidelines, produced by ATIS. According to section 1.4 of that document: At the direction of the NANPA, the access providers and the entities who are assigned CICs will be requested to provide access and usage information to the NANPA, on a semi-annual basis to ensure effective management of the CIC resource. (Holders of codes may respond to the request at their own election). Access provider and entity reports must be submitted to NANPA no later than January 31 for the period ending December 31, and no later than July 31 for the period ending June 30. It is also referenced in the NANPA Technical Requirements Document, which states at 7.18.6: CIC holders must provide a usage report to the NANPA per the industry CIC guidelines. . . The NAS must be capable of accepting CIC usage reports per guideline requirements on January 31 for the period ending December 31 and no later than July 31 for the period ending June 30. These reports may also be mailed and accepted by the NANPA in paper form. Finally, according to the NANPA website, if no local exchange carrier reports access or usage for a given CIC, NANPA is obliged to reclaim it. The semi-annual utilization and access reporting mechanism is described at length in the guidelines.

BloostonLaw contacts: Ben Dickens and Gerry Duffy.

AUGUST 1: LIVE 911 CALL DATA REPORTS FOR NON-NATIONWIDE PROVIDERS. Non-Nationwide Providers that do not provide coverage in any of the Test Cities must collect and report aggregate data based on the largest county within its footprint to APCO, NENA, and NASNA on the location technologies used for live 911 calls in those areas. Carriers should obtain spreadsheets with their company’s compliance data from their E911 service provider (e.g., Intrado / West). This is a recurring report due every six months — on first business day of second month after the six month period for which data is reported.

BloostonLaw Contact: Cary Mitchell.

AUGUST 1: 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. 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.

BloostonLaw Contacts: Ben Dickens and Gerry Duffy.

AUGUST 1: 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 1. 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. 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 and Gerry Duffy.

AUGUST 3: E911 Indoor Location Accuracy - Initial Implementation Plan and First Progress Report. All CMRS service providers must prepare and submit to the FCC an Initial Implementation Plan which describes their company’s plans for meeting the FCC’s improved indoor location accuracy requirements, as well as a related First Progress Report which describes their efforts to date toward meeting the plan. The FCC has not specified a particular format for these filings, so we are preparing a template that will combine both into a single report. Please contact us if you want us to prepare these filings on your company’s behalf.

BloostonLaw Contact: Cary Mitchell.

AUGUST 29: COPYRIGHT STATEMENT OF ACCOUNTS. The Copyright Statement of Accounts form plus royalty payment for the first half of calendar year 2014 is due to be filed August 29 at the Library of Congress’ Copyright Office by cable TV service providers.

BloostonLaw Contact: Gerry Duffy.

SEPTEMBER 1: FCC FORM 477, LOCAL COMPETITION AND BROADBAND REPORTING FORM. Three types of entities must file this form. (1) Facilities-based Providers of Broadband Connections to End User Locations: Entities that are facilities-based providers of broadband connections — which are wired “lines” or wireless “channels” that enable the end user to receive information from and/or send information to the Internet at information transfer rates exceeding 200 kbps in at least one direction — must complete and file the applicable portions of this form for each state in which the entity provides one or more such connections to end user locations. For the purposes of Form 477, an entity is a “facilities-based” provider of broadband connections to end user locations if it owns the portion of the physical facility that terminates at the end user location, if it obtains unbundled network elements (UNEs), special access lines, or other leased facilities that terminate at the end user location and provisions/equips them as broadband, or if it provisions/equips a broadband wireless channel to the end user location over licensed or unlicensed spectrum. Such entities include incumbent and competitive local exchange carriers (LECs), cable system operators, fixed wireless service providers (including “wireless ISPs”), terrestrial and satellite mobile wireless service providers, MMDS providers, electric utilities, municipalities, and other entities. (Such entities do not include equipment suppliers unless the equipment supplier uses the equipment to provision a broadband connection that it offers to the public for sale. Such entities also do not include providers of fixed wireless services (e.g., “Wi-Fi” and other wireless ethernet, or wireless local area network, applications) that only enable local distribution and sharing of a premises broadband facility.) (2) Providers of Wired or Fixed Wireless Local Telephone Services: Incumbent and competitive LECs must complete and file the applicable portions of the form for each state in which they provide local exchange service to one or more end user customers (which may include “dial-up” ISPs). (3) Providers of Interconnected Voice over Internet Protocol (VoIP) Service: Interconnected VoIP service is a service that enables real-time, two-way voice communications; requires a broadband connection from the user’s location; requires Internet-protocol compatible customer premises equipment; and permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network. Interconnected VoIP providers must complete and file the applicable portions of the form for each state in which they provide interconnected VoIP service to one or more subscribers, with the state determined for reporting purposes by the location of the subscriber’s broadband connection or the subscriber’s “Registered Location” as of the data-collection date. “Registered Location” is the most recent information obtained by an interconnected VoIP service provider that identifies the physical location of an end user. (4) Providers of Mobile Telephony Services: Facilities-based providers of mobile telephony services must complete and file the applicable portions of this form for each state in which they serve one or more mobile telephony subscribers. A mobile telephony service is a real-time, two-way switched voice service that is interconnected with the public switched network using an in-network switching facility that enables the provider to reuse frequencies and accomplish seamless handoff of subscriber calls. A mobile telephony service provider is considered “facilities-based” if it serves a subscriber using spectrum for which the entity holds a license that it manages, or for which it has obtained the right to use via lease or other arrangement with a Band Manager.

BloostonLaw contacts: Ben Dickens and Gerry Duffy.

SEPTEMBER 30: FCC FORM 396-C, MVPD EEO PROGRAM REPORTING FORM. Each year on September 30, multi-channel video program distributors (“MVPDs”) must file with the Commission an FCC Form 396-C, Multi-Channel Video Programming Distributor EEO Program Annual Report, for employment units with six or more full-time employees. Users must access the FCC’s electronic filing system via the Internet in order to submit the form; it will not be accepted if filed on paper unless accompanied by an appropriate request for waiver of the electronic filing requirement. Certain MVPDs also will be required to complete portions of the Supplemental Investigation Sheet (“SIS”) located at the end of the Form. These MVPDs are specifically identified in a Public Notice each year by the FCC.

BloostonLaw Contacts: Gerry Duffy and Sal Taillefer.

Calendar At-A-Glance

July
Jul. 17 – Reply comments are due on Wireless Broadband Infrastructure proceeding.
Jul. 17 – Reply comments are due on Wireline Broadband Infrastructure proceeding.
Jul. 17 – Comments are due on Broadband Title I Reclassification NPRM.
Jul. 21 – Reply comments are due on BDS for Model Based RoR Carrier Petition for Rulemaking.
Jul. 24 – Reply comments are due on Local Service Rate Floor NPRM.
Jul. 31 – FCC Form 507 (Universal Service Quarterly Line Count Update) is due.
Jul. 31 – Carrier Identification Code (CIC) Report is due.
Jul. 31 – International Traffic Data Report is due.
Jul. 31 – Deadline for comments refreshing the record on Toll Free Calling Access Charges.
Jul. 31 – Reply comments are due on Robocall Blocking proceeding.

August
Aug. 1 – FCC Form 502 due (North American Numbering Plan Utilization and Forecast Report).
Aug. 1 – FCC Form 499-Q (Quarterly Telecommunications Reporting Worksheet) is due.
Aug. 1 - Live 911 Call Data Reports for Non-Nationwide Providers due.
Aug. 3 – E911 Indoor Location Accuracy Initial implementation plan / first progress reports due.
Aug. 7 – Deadline to file for 3.65-3.7 GHz Grandfathered Protection Zone.
Aug. 15 – Deadline for reply comments refreshing the record on Toll Free Calling Access Charges.
Aug. 16 – Reply comments are due on Broadband Title I Reclassification NPRM.
Aug. 29 – Copyright Statement of Accounts is due.

September
Sep. 1 – FCC Form 477 due (Local Competition and Broadband Report).
Sep. 30 – FCC Form 396-C (MVPD EEO Program Annual Report).

Iridium Works to Become Maritime Distress Services Provider

Tuesday, July 11, 2017
Mission Critical Communications

Iridium Communications announced two key milestones allowing it to become the second recognized provider of Global Maritime Distress Safety System (GMDSS) services. Inmarsat is the only current recognized GMDSS provider.

Iridium expects the process to be completed during 2018, with Iridium GMDSS service to begin in 2020. In June, the International Maritime Organization's (IMO) Maritime Safety Committee (MSC) adopted new performance standards for GMDSS equipment and approved amendments to the Safety of Life at Sea (SOLAS) Treaty that pave the way for Iridium to become a recognized GMDSS service provider. The key remaining step in the approval process is an IMO resolution recognizing Iridium as a certified GMDSS mobile satellite service provider.

Iridium formally began the process to become a recognized GMDSS mobile satellite service provider in April 2013, and in March 2016, announced that the IMO's Maritime Safety Committee (MSC) Subcommittee on Navigation, Communication and Search and Rescue (NCSR) demonstrated broad support to incorporate Iridium as a mobile satellite GMDSS provider. The most recent meeting of the MSC in June updated the performance requirements for GMDSS equipment to reflect the new, enhanced capabilities mobile satellite companies can offer to the service.

Amendments to the SOLAS Treaty opened the door for GMDSS mobile satellite services to be provided by companies other than Inmarsat and will for the first time in history allow mariners a choice of GMDSS mobile satellite service provider. These developments pave the way for Iridium, and other networks, to become recognized GMDSS service providers.

"We have been working collaboratively with the IMO and member states for several years," said Brian Pemberton, vice president and general manager, strategic planning at Iridium. "The IMO and the maritime community recognize that GMDSS needs to modernize, and additional service providers is one part of that.

"Most importantly, we worked closely with the IMO to establish new standards that will bring choice and competition to this critical service area for the first time. Competition is key to ensuring that mariners are provided best-in-class communications for safety purposes, which is a must out at sea."

Arctic shipping routes are becoming more heavily used, including the Northern Sea Route and Northwest Passage, resulting in an increased need for reliable emergency communications, Iridium said in a statement.

The Iridium network is a constellation of 66 low-Earth orbit (LEO), cross-linked satellites that provide low-latency satellite communications to the entire world, including the poles. The company is in the process of replacing its existing network with new satellites, known as Iridium NEXT. SpaceX is launching the next-generation constellation through a series of eight launches, with two successful launches complete. It will deliver faster speeds, higher throughputs and act as an innovation engine for Iridium partners and customers.

Brad Dye, Ron Mercer, Allan Angus, Vic Jackson, and Ira Wiesenfeld are friends and colleagues who work both together and independently, on wireline and wireless communications projects.

Click here for a summary of their qualifications and experience. Each one has unique abilities. We would be happy to help you with a project, and maybe save you some time and money.

Note: We do not like Patent Trolls, i.e. “a person or company who enforces patent rights against accused infringers in an attempt to collect licensing fees, but does not manufacture products or supply services based upon the patents in question.” We have helped some prominent law firms defend their clients against this annoyance, and would be happy to do some more of this same kind of work.

Some people use the title “consultant” when they don't have a real job. We actually do consulting work, and help others based on our many years of experience.

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I look in hope and fear;
But grateful take the good I find,
The best of now and here.

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