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Frontier Communications is being sued by at least 150 disgruntled Internet customers. (article follows)

Although I am not involved in the lawsuit, I am a "disgruntled" customer.

I think I already told the story about getting my telephone line (aDSL) cut one morning. As I was driving to town a little while later — about two or three hundred yards from my house — I came across two neanderthals working on the telephone line. I stopped and told them that they had just cut my line and they assured me it would be reconnected in a few minutes. "If it doesn't work, call customer service," one of them said.

Sure enough when I got back home their truck was gone and my line was still dead. I called customer service and explained what happened and they said the soonest they could have a technician fix the line would be in two weeks. What? Two weeks!

I asked to escalate the issue to management and issued a formal complaint. Eventually I was promised a one-monh refund on my bill but that didn't happen until I complained again a couple of months later.

So a technician did come in two weeks and repaired the line. He was a nice guy and even installed a new modem/router.

The service I have now is called "fiber to the neighborhood." That just means that a high speed fiber optic cable gets dropped into a neighborhood hub and the last several hundred yards of my (aDSL service asymmetrical Digital Subscriber Line) go to my house over the old copper-wire line. It is called asymmetrical since the upload speed is much slower than the download speed, which is OK because most of us do a lot more downloading than we do uploading.

My current Internet speed is, 17.77 Mbps download and 1.47 Mbps upload. (Not very good but the best I can get here.)

By the way, the fiber optic line had been buried about two or three hundred yards from my house for several years before they got around to connecting it into the neighborhood hub. They said that the contractor had forgotten to do the connection and was now down working in Arkansas.

Maybe I should try to get included in the lawsuit?

The Internet was designed to be failure proof. Simply put, if any main line would happen to get cut in case of accident or war, traffic would be automatically re-routed over another line/link.

This analogy explains Internet routing.

Imagine this is how the Internet would look if it was made up of water-filled canals.

Let's use Venice, or Amsterdam as examples. Imagine there are no telephones so everyone communicates by writing a note on a piece of paper with the destination address, putting it in a wine bottle, putting a cork in it, and then throwing it into the nearest canal.

The bottle then drifts down the canal to the first intersection with another canal.

At each corner, where the canals cross, there is a man (or woman) called a "router." It is this person's job to take each bottle out of the water and look at the destination address. Now that the router knows the correct destination s/he looks down each canal and checks to see if it is open. If one canal is blocked due maybe to a big wreck of two gondolas crashing, then s/he throws the bottle into another canal that is open.

And so the bottle floats down the canals, from router to router, until it gets to its destination.

Long messages are put into several different bottles and get put back together in the right order, like cars on a train. This happens at the destination. If one of the bottles is cracked, missing, or the message in it is not clear, the router just requests a repeat of that bottle (message portion).

In the real Internet the routers are not people, they are just computerized switches that route (or direct) Internet traffic. WHERE: You may think that your Internet traffic goes straight to its destination, when actually parts of it may even go through other countries. HOW: Traffic is routed, via satellite links, undersea cable, landlines, fiber optics, and microwave links. WHEN: Just like car traffic—the more cars, the slower the traffic.

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NO POLITICS HERE

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.

A new issue of the Wireless Messaging Newsletter is posted on the web each week. A notification goes out by e-mail to subscribers on most Fridays around noon central US time. The notification message has a link to the actual newsletter on the web. That way it doesn’t fill up your incoming e-mail account.

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.

We are having a cold spell in Southern, Illinois

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 own opinions.

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Frontier often under fire for its services

By FRED PACE July 25, 2019

Sholten Singer/The Herald-Dispatch Communications vehicles are seen at a facility in Altizer on Tuesday, July 23, 2019, in Huntington. The company is being sued by at least 150 disgruntled Internet customers, and has been ordered to conduct an audit of its operations by the West Virginia Public Service Commission (PSC).

HUNTINGTON - In West Virginia, Frontier Communications has been routinely under fire for its Internet service and its landline phone service, with dozens of formal complaints being lodged against the company just in recent weeks.

Currently, the company is being sued by at least 150 disgruntled Internet customers, it has been ordered to conduct an audit of its operations by the West Virginia Public Service Commission and the company has been on the radar of both state and federal officials over alleged poor service. Many actions date back several years.

Monty Fowler was so upset by his Internet service from Frontier Communications at his Huntington home that he recently filed a formal complaint with the Federal Communications Commission.

"I would like the FCC to hold Frontier Communications accountable for both its poor DSL (Internet) service and its nonexistent customer communication when there is a problem," he said.

Fowler said his Internet service became very slow around June 20 and it took over a month to get some service restored.

"The Internet is mostly working, but occasionally quits for a few minutes, freezing web pages or whatever I'm working on," he said. "This is beyond pathetic."

Fowler was one of more than 200 people across the state who emailed, messaged or commented about Frontier services after The Herald-Dispatch sought feedback from Facebook users regarding Frontier. Many said they have been without Internet or telephone landline service for days, weeks and even months in some cases. Many said they have reported the issues to Frontier, but have received no resolutions to issues ranging from daily service outages to poor customer service and more.

Joe Fincham, of Lesage, said slow Internet speeds and continuous outages are routine with the Frontier Internet service he receives.

"Internet speed tests routinely show slower than paid-for speeds," he said. "Service is routinely unavailable about four to eight times per day for 15 to 30 minutes at a time. Also, service routinely cuts off every time it rains."

Vickie Finlay says she moved from the Westmoreland area to the Southside neighborhood of Huntington and had problems when she tried to get Internet service at her new location.

"Frontier was supposed to send a tech with a modem on July 3. They blew me off," she said. "Then I get a message that they will be there on the 15th. I waited. They blew me off again."

After several other broken promises by Frontier, according to Finlay, she said she canceled her account.

Connie Walker Laishley, owner of Appalachian Forest Herbs in Huntington, says Frontier's Internet outages happen to her business on a daily basis.

"Facebook is the main venue for my business, and we have outages three and four times a day," she said. "Also my security system is down without the Internet"

Kristy Watts lives on Cotton Hill Road in Fort Gay and has both Frontier Internet and telephone landline service.

"My landline phone service goes out every time it rains, and I have filed many complaints," she said. "My Internet doesn't go out, but it's so slow it's not worth having. My mother and my sister live around me and they have the same issues. It's just so aggravating."

Hundreds of others reported similar issues with both Frontier's Internet and telephone landline services.

Bob Elek, director of public relations for Frontier Communications' South Region, says it's not uncommon for there to be some type of outage every day.

"Some outages are minor. Some are not. But if we don't have specific customer information about the alleged problem, it's difficult to respond to what may or may not be happening," he said. "In our large, mountainous, rural territory in West Virginia, service interruptions happen. There are hundreds of service requests daily, often in difficult-to-maintain areas."

Elek said the company works to promptly address service interruptions that occur from time to time because of severe weather events, vehicle accidents and third-party construction damage to Frontier's facilities, as well as many other causes.

"Uncontrollable events like severe weather, construction crews cutting cables, cars hitting telephone poles or equipment cabinets or a variety of such causes can cause service disruptions and delay response-and-restore efforts," he said.

Elek says Frontier serves approximately 300,000 of the 2.26 million voice customers in the state and it serves the most costly and difficult-to-serve areas.

"Frontier provides service in the most rural areas of West Virginia where other providers choose not to invest to deliver service and where the challenges of remoteness are greatest," he said. "We continue to evaluate and execute strategies to improve our service." Complaints about Frontier's Internet speeds can be a challenge, too, Elek added.

"For Internet service, we strive to deliver the highest speeds, but the available speed depends on multiple variables, including, especially in rural areas, the distance that the customer's location is from our Internet equipment," he said. "All areas where Frontier provides service are open to competition from any provider that chooses to invest in and provide service there, including several satellite providers that serve nearly all areas in West Virginia. We price our services very competitively and offer a high-value option."

According to the West Virginia Attorney General's Consumer Protection Division, the agency has received 230 complaints against Frontier so far in 2019.

"Fifty-one of those complaints were filed in June and July alone," said Curtis Johnson, press secretary for the office.

Johnson reported the agency received 312 complaints during the 2018 calendar year.

Between 2013 and 2015, the Attorney General's Office reported receiving multiple complaints from customers paying for Frontier's high-speed service, which advertised Internet speeds up to 6 megabits per second.

West Virginia Attorney General Patrick Morrisey sued Frontier and announced a $160 million settlement with the company in December 2015.

In August 2017, Morrisey gave an update saying the agreement with Frontier marked the largest independently negotiated consumer protection settlement in the history of the Mountain State. It required Frontier to invest at least $150 million in capital expenditures to increase Internet speed in the affected areas and give those customers lower monthly rates.

According to the update in 2017, the company spent $83.9 million in capital expenditures, which allowed increased Internet speed for 11,192 customers in the state.

Due to several continuing complaints, the West Virginia Public Service Commission, or PSC, filed an order in August 2018 for an audit of Frontier operations. The PSC ordered a focused management audit of Frontier to determine if Frontier was operating efficiently, utilizing sound management practices and to identify those areas where Frontier was operating inefficiently.

After the PSC withheld approval of the auditor chosen by Frontier, this past Friday the company filed a recommendation for a supplemental "request for proposal," or RFP.

"Frontier engaged in an objective bid award process weighing all factors; however, the PSC felt pricing was overemphasized in the evaluation," Elek said. "We will act in good faith to comply fully with the PSC's directives."

The PSC has not responded to the filing as of Monday, according to Susan Small, a spokesperson for the PSC. Additional information is available on the commission website at www.psc.state.wv.us by referencing Case No. 18-0291-T-P.

In July, U.S. Sen. Joe Manchin, D-W.Va., sent a letter to Ajit Pai, chairman of the Federal Communications Commission (FCC), to discuss the incorrect broadband coverage maps of West Virginia and the formation of a public feedback system to better assess broadband coverage across rural states like West Virginia.

In the letter, Manchin included the results of speed tests taken in Cabins, West Virginia, showing that the coverage provided by Frontier Communications in the area is well below the FCC's definition of broadband coverage.

Manchin also reported receiving several complaints regarding the company's telephone landline service and sent a letter to Frontier Communications Corp. CEO Dan McCarthy to address the issue.

"In times of crisis, no one should ever have to think twice about whether he or she will be able to call for help. Unfortunately, I have been alerted of several instances where my constituents who utilize Frontier's landline service have not been able to complete calls due to service outages," the letter said.

Elek confirmed that Frontier did receive Manchin's letter.

"Frontier shares Senator Manchin's dedication to safety and takes its commitment to serve West Virginians and support 911 services seriously," Elek said. "One key problem we must resolve together is that while Frontier only serves about 10% of the 2.26 million telephone lines in West Virginia, Frontier has 100% of the obligation to provide traditional telephone voice service to customers in the most rural, remote and high-cost areas of the state. Frontier is actively working with the West Virginia Public Service Commission and other state officials to address the continued availability of quality, affordable landline service in these high-cost areas."

Follow reporter Fred Pace at Facebook.com/FredPaceHD and via Twitter @FredPaceHD.

Filing service issues, complaints:

• Frontier customers can call Frontier's toll-free customer service telephone number to report service issues at 800-921-8101.
• Customers concerned with issues about service they receive from a public utility can file a complaint with the Attorney General's Consumer Protection Division at 800-368-8808 or visit http://www.wvago.gov.
• Complaints about a public utility's service can be sent to the West Virginia Public Service Commission, C/O Executive Secretary, 201 Brooks St., Charleston, WV 25323.

Paging Transmitters 150/900 MHz

The RFI High Performance Paging Transmitter is designed for use in campus, city, state and country-wide paging systems. Designed for use where reliable simulcast systems where RF signal overlap coverage is critical.

• Commercial Paging systems.
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• Demand Response Energy Grid Management.

Built-in custom interface for Prism-IPX ipBSC Base Controller for remote control, management and alarm reporting.

• Use as a stand-alone unit or in wide area network.
• Mix with other transmitter brands in an existing paging network.
• Adjustable from 20-250 watts.
• 110/240 VAC or 48VDC.
• Absolute Delay Correction.
• Remote Diagnostics.
• Configurable alarm thresholds.
• Integrated Isolator.
• Superb Reliability.
• Improved amplifier efficiency.
• Most reliable high-powered paging transmitter available.

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Back To Paging

Still The Most Reliable Protocol For Wireless Messaging!

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GTES is no longer offering support contracts. GTES was the original group from Vancouver that was setup to offer support to customers that wanted to continue with the legacy Glenayre support. Many U.S. customers chose not to use this service because of the price and the original requirement to upgrade to version 8.0 software (which required expensive hardware upgrades, etc.). Most contracts ended as of February 2018.

If you are at all concerned about future support of Glenayre products, especially the “king of the hill” the GL3000 paging control terminal, I encourage you to talk to Vaughan about a service contract and please tell him about my recommendation.

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Board of Advisors

The Board of Advisor members are people with whom I have developed a special rapport, and have met personally. They are not obligated to support the newsletter in any way, except with advice, and maybe an occasional letter to the editor.

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Here's What's New in iOS 12.4, macOS Mojave 10.14.6, tvOS 12.4, and watchOS 5.3

Users are encouraged to update their devices

Jul 24, 2019 14:34 GMT
By Marius Nestor

Apple released the iOS 12.4, macOS Mojave 10.14.6, tvOS 12.4, and watchOS 5.3 software updates for all supported devices, adding more security improvements and bug fixes.

After a few weeks of development, the iOS 12.4 (build 16G77), macOS Mojave 10.14.6 (build 18G84), tvOS 12.4 (build 16M568), and watchOS 5.3 (build 16U569) software updates are here and ready for download via OTA (Over-the-Air) update mechanism on all supported iPhone, iPad, Mac, Apple TV, and Apple Watch devices.

As for the changes included in this new maintenance releases, we can mention that iOS 12.4 introduces an iPhone migration feature that lets users wirelessly transfer their data from an old iPhone device to a new one during the first-time setup process. Of course, for this to work, the newer device needs to run the iOS 12.4 release.

Furthermore, iOS 12.4 adds support for FaceTime audio and video calling on iPhone and iPad devices sold in Pakistan, addresses the recent security issue affecting the Walkie-Talkie app on the Apple Watch, thus re-enabling the Walkie-Talkie functionality for all supported Apple Watch models, and adds support for HomePod in Japan and Taiwan.

What's new in macOS Mojave 10.14.6, watchOS 5.3, and tvOS 12.4

The macOS Mojave 10.14.6 release is here to address an issue that prevented the creation of a new Boot Camp partition on iMac and Mac mini computers with Fusion Drive, repair a problem that could have lead to a hang during a restart on all supported Macs, and fix a graphic issue that may occur when waking your Mac from sleep.

Other than that, the macOS Mojave 10.14.6 update improves the reliability of the file sharing functionality over SMB (Samba) and addresses an issue that may have caused full-screen videos to appear black on Mac mini computers. On the other hand, the tvOS 12.4 release introduces more performance improvements and bug fixes, along with various refinements to the new TV app.

The watchOS 5.3 release adds the ECG app and irregular heart rhythm notifications on all supported Apple Watch Series 4 models sold in Canada and Singapore, and fixes the recent security vulnerability in the Walkie-Talkie app, which could allow someone to listen to the conversations of another person's iPhone without consent.

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Who We Are

Prism-IPX is a leader in providing reliable communications systems using modern designs to meet today’s demands for critical message alerting and delivery. Prism-IPX designs versatile and robust Critical Message Management systems using paging and other wireless technologies for high performance and dependable communications.

What We Make

Prism-IPX Systems products include full-featured radio paging systems with VoIP input, IP based transmitter control systems and paging message encryption. Other options include e-mail messaging, remote switch controllers, Off-The-Air paging message decoders and logging systems.

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Windows 10 20H1 has a lot of changes in store for the operating system

By Mark Knapp
July 23, 2019

Operating Systems The big things we know will change and how

(Image credit: TechRadar)

Windows 10 updates keep coming whether you install them or not. They generally bring a whole host of bug fixes and new features, but they've also been known to come with their own share of issues.

While we don't know what possible problems next year's Windows 10 Version 20H1 will introduce, we've got some details on the new features coming. Builds of Version 20H1 have been available to Fast Ring Insider testers since early this year, and that's made plenty of information available.

We're going to lay out all of the most exciting, interesting, and generally useful features that are coming up in Windows 10 20H1 within — you guessed it — the first half of 2020.

Cut to the chase

• What is it? Windows 10 20H1 is next major version of Windows
• When is it out? Windows 10 20H1 is expected in the first half of 2020
• How much does it cost? Windows 10 20H1 will be free for all users

Windows 10 20H1 brings a new look

We've seen more than one hint that Version 20H1 could be making a move toward a more rounded design instead of the sharp angles seen currently in Windows 10. This would extend from windows and buttons to sliders and pop-up dialog boxes.

This would work to provide some more consistency between the desktop user interface and apps, as well as aligning it more with modern web and app style. This change isn't certain though, but has been hinted at more than once.

Windows 10 20H1 brings new virtual desktop names

When you make virtual desktops in Windows 10 right now, they get rather unhelpful, numbered names: Desktop 1, Desktop 2, etc.

Version 20H1 should introduce the option to create custom names for each virtual desktop. So, if you use virtual desktops to separate work and play or various projects, you can make sure each is clearly labeled for which project each is dedicated to.

And, as Windows Central notes, the custom virtual desktops can be saved so they aren't reset after each reboot.

Windows 10 20H1 brings commitment to Windows Hello

Many computers are now built with fingerprint scanners or advanced cameras that provide facial recognition to work with Windows Hello. This lets you sign on without a password, but Windows still requires a password for the account even if you don't have to use it to sign on every time.

The 20H1 update may include an option to make your device password-less, letting it exclusively rely on Windows Hello for signing into your Microsoft account, Windows Central reports.

• Here's what we know about macOS Catalina

Related product: Microsoft Windows 10 Home

Our Verdict:

With the May 2019 updates, Windows 10 is more secure, reliable and efficient than ever, introducing features that could genuinely save you time and frustration as well as keep your computer protected. Of course, there’s always room for improvement, but Windows 10 is now better than ever and still continues to evolve with a slew of constant updates.

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Internet Protocol Terminal

The IPT accepts Internet or serial messaging using various protocols and can easily convert them to different protocols, or send them out as paging messages.

An ideal platform for hospitals, on-site paging applications, or converting legacy systems to modern protocols.

Additional/Optional Features

• Database of up to 5000 subscribers.
• 4 serial ports on board.
• Up to 8 phone lines (DID or POTS).
• Can be configured for auto-fail-over to hot swap standby.
• 1RU rack mount unit appliance—no moving parts.
• Easily secure legacy system messages leaving site for HIPAA compliance.
• Only purchase the protocols/options you need.
• Add Paging Encryption for HIPAA compliance on site.

Prism-IPX Systems LLC.

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Paging Data Receiver PDR-4

The PDR-4 is a multi-function paging data receiver that decodes paging messages and outputs them via the serial port, USB or Ethernet connectors.

Designed for use with Prism-IPX ECHO software Message Logging Software to receive messages and log the information for proof of transmission over the air, and if the data was error free.

• Option—decode capcode list or all messages.
• Large capcode capacity.
• Serial, USB and Ethernet output.
• POCSAG or FLEX page decoding, special SA protocols.
• Receivers for paging bands in VHF, UHF, 900 MHz.
• Message activated Alarm Output.
• 8 programmable relay outputs.
• Send notifications of a system problem.

• Synthesized Receiver Tuning.
• Selectivity better than 60 dB.
• Frequencies 148-174, 450-470, 929-932 MHz.
• Image Rejection better than 55 dB.
• Spurious Rejection better than 55 dB.
• Channel Spacing 12.5 or 25 kHz.
• Power 5VDC.
• Receiving Sensitivity 5µV at 1200 bps.

Prism-IPX Systems LLC.

11175 Cicero Dr., Alpharetta, GA 30022
Ph: 678-242-5290 e-mail: sales@prism-ipx.com
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Wireless Network Planners
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R.H. (Ron) Mercer Consultant 217 First Street East Northport, NY 11731
Telephone: 631-786-9359
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wirelessplannerron@gmail.com

NYU Professor Theodore S. Rappaport named to Wireless Hall of Fame

PRNewswire
July 25, 2019 11:00am

Comments BROOKLYN, N.Y., July 25, 2019 /PRNewswire/ — Theodore S. Rappaport, a New York University professor and founding director of the research center NYU WIRELESS will be inducted into the Wireless History Foundation (WHF) Wireless Hall of Fame at the Foundation's Awards Dinner in Los Angeles on October 23rd. Rappaport also recently became the recipient of the Institute of Electrical and Electronics Engineers (IEEE) 2020 Eric E. Sumner Award, named in honor of the late IEEE President Eric E. Sumner, who was instrumental in developing early switching systems. He will receive the Sumner medal at the 2019 IEEE Global Communications Conference in Hawaii in early December.

Both the IEEE and Wireless History Foundation are recognizing Rappaport — who also founded academic wireless research centers at the University of Texas and Virginia Tech — as one of the preeminent thought leaders in the wireless field and for groundbreaking academic research and entrepreneurship that have blazed a path for modern wireless communication systems.

Others to be inducted into the Wireless Hall of Fame in October are Android founders Rich Miner, Andy Rubin, Nick Sears and Chris White; and pioneer of two-way voice systems and paging Lawrence D. Garvey (posthumously).

Rappaport's research in radio wave propagation, wireless communication system design, and broadband wireless communications circuits and systems at millimeter wave (mmWave) frequencies (30 to 300 gigahertz) paved the way for the commercialization of fifth-generation (5G) wireless technology. As 5G rolls out, it will bring broadband speeds to wireless communication, thereby potentially revolutionizing medicine, enabling autonomous vehicles, and inexpensively connecting rural communities to the digital world.

Before Rappaport published his seminal 2013 paper, "Millimeter Wave Mobile Communications for 5G Cellular: It Will Work," in an IEEE journal, few experts acknowledged the possibilities of tapping that underutilized spectrum. Now, NYU WIRELESS, which Rappaport launched upon arriving at the NYU Tandon School of Engineering in 2012, is moving well beyond 5G research.

Rappaport's latest comprehensive overview, "Wireless Communications and Applications above 100 GHz: Opportunities and Challenges for 6G and Beyond," highlights the technical challenges and opportunities for the coming decades, particularly in the terahertz (THz) electromagnetic spectra. Along with other NYU WIRELESS researchers, he is exploring THz for ultra-fast, high-capacity data transmission and revolutionary applications for communications, medical imaging, precise position location, semiconductor testing, and new kinds of spectroscopy.

"Ted Rappaport has been a linchpin in making NYU a world leader in the field of wireless communications, as well as an educator who has inspired and nurtured the next generation of innovators in the field," said NYU Tandon Dean Jelena Kovačević. "We congratulate him on these latest well-deserved honors from IEEE and the Wireless History Foundation and are eager to watch as he helps usher in the new era of 5G and beyond."

Rappaport is the David Lee/Ernst Weber Professor of Electrical Engineering at NYU Tandon, a professor of computer science at NYU Courant Institute of Mathematical Sciences, and a professor of radiology at the NYU School of Medicine. He is serving his third term on the Technological Advisory Council of the Federal Communications Commission and was recently elected a fellow of the National Academy of Inventors.

Among his other honors are the 1990 Marconi Young Scientist Award, 1999 IEEE Communications Society Stephen O. Rice Prize, 2002 Fredrick E. Terman Outstanding Electrical Engineering Faculty Award from the American Society for Engineering Education, 2005 IEEE Vehicular Technology Society Stuart F. Meyer Award, 2011 IET Sir Monty Finniston Medal for achievement in engineering and technology, 2015 IEEE Donald G. Fink Paper Prize Award, 2017 IEEE VTS Neal Shepherd Memorial Best Propagation Paper Award, and 2018 Armstrong Medal from the Radio Club of America. He has more than 100 U.S. or international patents issued or pending and has authored, co-authored, and co-edited 18 books, including the world's best-selling books on wireless communications, millimeter wave communications, and smart antennas.

About the New York University Tandon School of Engineering
The NYU Tandon School of Engineering dates to 1854, the founding date for both the New York University School of Civil Engineering and Architecture and the Brooklyn Collegiate and Polytechnic Institute (widely known as Brooklyn Poly). A January 2014 merger created a comprehensive school of education and research in engineering and applied sciences, rooted in a tradition of invention and entrepreneurship and dedicated to furthering technology in service to society. In addition to its main location in Brooklyn, NYU Tandon collaborates with other schools within NYU, one of the country's foremost private research universities, and is closely connected to engineering programs at NYU Abu Dhabi and NYU Shanghai. It operates Future Labs focused on start-up businesses in downtown Manhattan and Brooklyn and an award-winning online graduate program. For more information, visit http://engineering.nyu.edu.

About NYU WIRELESS NYU WIRELESS
is a vibrant academic research center that is pushing the boundaries of wireless communications, sensing, networking, and devices. Centered at NYU Tandon and involving leaders from industry, faculty, and students throughout the entire NYU community, NYU WIRELESS offers its industrial affiliate sponsors, students, and faculty members a world-class research environment that is creating fundamental knowledge, theories, and techniques for future mass-deployable wireless devices across a wide range of applications and markets. Every April, NYU WIRELESS hosts a major invitation-only wireless summit, in cooperation with Nokia Bell Laboratories, for the center's industrial affiliates and thought leaders throughout the global telecommunications industry. For more information, visit wireless.engineering.nyu.edu.

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.

“If you would know the road ahead, ask someone who has traveled it.”
— Chinese Proverb

Remote AB Switches

ABX-1 switches are often used at remote transmitter sites to convert from old, outdated and unsupported controllers to the new modern Prism-IPX ipBSC base station controllers. Remotely switch to new controllers with GUI commands.

ABX-1

ABX-3 switches are widely used for enabling or disabling remote equipment and switching I/O connections between redundant messaging systems.

ABX-3

Common Features:

• RJ45 for A, B and Common connectors.
• Manual push button or use Prism IP commands to switch one or more relays.
• Single or Dual Port Control card for IP or Serial connection.
• Form C relay—control local connection.
• Power Loss Indicator.
• Rear Panel Connector for controlling the switch externally.
• Power Source: 5VDC for ABX-1; 12VDC for ABX-3.

Prism-IPX Systems LLC.

11175 Cicero Dr., Alpharetta, GA 30022
Ph: 678-242-5290 e-mail: sales@prism-ipx.com
prism-ipx.com

New FAA Regs Will Require Markings For Farmland Towers Under 200 Feet

New FAA regulations will require landowners to mark any towers between 50-feet and 200-feet on their property, as well as include the towers in a new database the FAA is developing, reports General Aviation News. Previously, towers under 200-feet were not subject to federal marking requirements.

The new requirements stem from provisions in the FAA Extension, Safety and Security Act of 2016 and the FAA Reauthorization Act of 2018.

Meteorological evaluation towers (METs) meeting the requirements stipulated in the bills must be both marked and logged into the FAA database. Communication towers of the same size have the option to be either be marked or logged in the FAA database, according to the account.

The FAA Reauthorization Act of 2018 requires this database to be functional by October. The FAA is also finalizing the marking requirements, however they are expected to be similar to the standards found in FAA Advisory Circular 70/7460-1L, according to General Aviation News.

Section 2110 of the Act on Tower Marking states: “The Administrator shall consider excluding towers located in a State that has enacted tower marking requirements according to the [FAA’s] recommended guidance for the voluntary marking of meteorological evaluation towers erected in remote and rural areas that are less than 200 feet above ground level to enhance the conspicuity of the towers for low level agricultural operations in the vicinity of those towers.”

North Dakota farmer and aerial applicator Brian Rau has a 96-foot Real Time Kinematic tower on his property. RTK towers supplement the GPS systems of automated ground-based farm equipment. He added fluorescent ball markers within the structure’s skeleton soon after it was converted from a communications tower to an RTK tower. “Seeing the growth of communication towers in North Dakota and across the county, I knew it was important to both mark and properly log the tower,” Rau told General Aviation News.

FAA Advisory Circular 70/7460-1L on obstruction marking and lighting details the ways different types of obstructions may be marked. The document provides specs on lighting systems, colors and light intensities. As an alternative to lighting, the document also explains tools for the “unlighted marking” of obstructions. This includes paint colors and patterns, as well as specifications for guy wire sleeves and high-visibility spherical markers.

Rau chose the latter option for marking his RTK tower. “The ball markers seemed the easiest for an existing galvanized tower, and they really improved [its] visibility,” he said.

Landowners are encouraged to submit an obstruction to the FAA’s Daily Digital Obstacle File by emailing the tower’s height and coordinates to 9-AJV-532-OBSTData-REQ@faa.gov.

By Leslie Stimson, Inside Towers Washington Bureau Chief

Selected portions [sometimes more — sometimes less — sometimes the whole updates] 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 kind permission from the firm. The firm's contact information is included at the end of this section of the newsletter.

Electronic Notice Rule for MVPD Providers Effective July 18

As of July 18, cable operators and other multichannel video programming distributors (MVPDs) are permitted to fulfill their Subpart T notice requirements via electronic delivery. Subpart T notices include information about channel deletions; service change notices; contact information for local franchise authorities; notice of charges for various services and service changes; and information about the basic service tier, broadcast signal availability, and consumer equipment compatibility of subscriber. MVPDs may also provide privacy information and may respond to consumer requests and complaints via e-mail in certain circumstances.

BloostonLaw Contacts: Gerry Duffy and John Prendergast.

Headlines

Chairman Pai Announces Two FCC Modernization Proposals

On July 22, FCC Chairman Ajit Pai issued a Press Release announcing with two new proposals to modernize and streamline the agency’s processes. Under the first, the FCC would continue the agency’s move toward electronic filing and correspondence by fully transitioning the Universal Licensing System—the agency’s largest licensing system—from paper to electronic format. The second proposal would expedite the Commission’s hearing processes by expanding the use of written hearings (i.e. hearings conducted without live testimony).

“As the communications marketplace is being transformed by the digital revolution, we must continue to modernize our own operations.” said Chairman Pai. “That’s why I’m introducing two new proposals to update and streamline our processes for the digital age. By transitioning more records and communications from paper to electronic format, we can save money and increase our efficiency. And by streamlining our hearing rules, we can resolve disputes more quickly, which will benefit the private sector as well as the Commission. I hope that my colleagues will join me in supporting these good-government initiatives.”

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

FCC Announces Counties Where Conditional Forbearance from Lifeline Voice Applies

On July 22, the FCC issued a Public Notice announcing the counties in which conditional forbearance from the obligation to offer Lifeline-supported voice service applies, pursuant to the Commission’s 2016 Lifeline Order. This forbearance applies only to the Lifeline voice obligation of eligible telecommunications carriers (ETCs) that are designated for purposes of receiving both high-cost and Lifeline support (high-cost/Lifeline ETCs), and not to Lifeline-only ETCs. This conditional forbearance will apply effective September 21.

As we reported in a previous edition of the BloostonLaw Telecom Update the 2016 Lifeline Order established conditional forbearance from Lifeline voice obligations in targeted areas where certain competitive conditions were met. To accomplish this forbearance, the FCC releases a yearly public notice announcing the counties in which the competitive conditions are met. In particular, the FCC granted forbearance from high-cost/Lifeline ETCs’ obligation to offer and advertise Lifeline voice service in counties where the following conditions are met: (1) 51% of Lifeline subscribers in the county are obtaining broadband Internet access service; (2) there are at least three other providers of Lifeline broadband Internet access service that each serve at least 5% of the Lifeline broadband subscribers in that county; and (3) the ETC does not actually receive federal high-cost universal service support.

A list of the counties meeting these requirements and therefore eligible for forbearance can be found here.

BloostonLaw Contacts: Mary Sisak and Sal Taillefer.

FCC Seeks Additional Comment in 3.7-4.2 GHz Band Proceeding

On July 19, the FCC issued a Public Notice seeking supplemental comments on issues raised by commenters in response to July 2018 Notice of Proposed Rulemaking in the 3.7-4.2 GHz Band Proceeding, GN Docket No. 18-122. Comments are due August 7, and reply comments are due August 14.

As we reported in a previous edition of the BloostonLaw Telecom update, the FCC sought comment on several approaches, including auction-based approaches, for making some or all of the 3.7-4.2 GHz band (C-Band) available for terrestrial, flexible use. The FCC also sought comment on other issues essential to the introduction of new terrestrial wireless services in the band, including incumbent protection criteria, technical and licensing rules, and appropriate methodologies for transitioning or protecting existing Fixed Satellite Service and Fixed Service operators in the band.

In response to the Notice, commenters proposed auction-based approaches and other transition mechanisms to introduce new flexible-use licensing in the band. Commenters also espoused different views on appropriate repurposing methodologies, Fixed Satellite Service earth station protection criteria, technical rules, and other issues raised in the Notice. The FCC seeks additional comment on these recent filings:

• The ACA Connects Coalition, which collectively represents both incumbent C-band earth station users and wireless providers that seek to use this spectrum to provide 5G services, recently submitted a joint proposal for repurposing a large portion of the C-band for 5G use. Their proposal consists of three key elements that would make 370 megahertz of C-band spectrum available for flexible wireless use on a nationwide basis: (1) a Commission-driven auction that would award new terrestrial licenses and assign obligations for transition costs; (2) a plan to transition certain Fixed Satellite Service earth station operators to fiber; and (3) a plan for satellite operators to repack remaining earth station users to the upper portion of the band.
• AT&T submitted comments responding to the C-Band Alliance’s proposed technical criteria for operations in the band, particularly with respect to co-existence with incumbent Fixed Satellite Service earth stations. AT&T asserts that the C-Band Alliance’s proposed technical criteria would constrain 5G deployment, and it proposes an alternate band plan to address its concerns. AT&T recommends dividing the 3.7-4.2 GHz band into three segments: (1) a largely unrestricted mobile terrestrial 5G segment in the bottom of the band (“Unrestricted Licenses”); (2) “Adjacent Licenses” in the middle of the band that would have to coordinate with or mitigate impact on Fixed Satellite Service; and (3) remaining Fixed Satellite Service spectrum in the top of the band. Unrestricted Licenses could operate using full power and would not be obligated to coordinate with Fixed Satellite Service earth stations; Adjacent Licenses would operate using lower power or subject to other limitations, or would be obligated to coordinate with nearby Fixed Satellite Service earth stations.
• WISPA, Google, and Microsoft filed a study conducted by Reed Engineering, which analyzed Fixed Satellite Service and fixed wireless point-to-multipoint co-channel coexistence in the 3.7-4.2 GHz band. Among other conclusions, the Reed Study suggests that exclusion zones of about 10 kilometers are sufficient to protect most Fixed Satellite Service earth stations from harmful interference caused by properly-engineered co-channel point-to-multipoint broadband systems. The propagation model used in the study relied on Fixed Satellite Service earth station characteristics that require them to point upwards towards the geostationary satellite arc. Thus, the earth stations are specifically designed to mitigate their response to signals arriving from the horizon, such as terrestrial point-to-multipoint links.

The FCC seeks comment in particular on the technical issues raised by the ACA Connects Coalition proposal, AT&T’s proposal, and the Reed Study, and on the questions raised therein, such as what are the appropriate interference thresholds and protection criteria, how should they be modeled, and under what deployment assumptions?

Carriers interested in commenting should contact the firm for more information.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

FCC Lifts Freeze on Full Power and Class A Stations for Certain Repacked Stations

On July 22, the FCC issued a Public Notice lifting the freeze imposed on April 5, 2013 on the filing and processing of minor modification applications that would increase a full power television station’s noise-limited contour or a Class A station’s protected contour in one or more directions beyond the station’s authorized facilities. This action is limited to full power and Class A television stations that were reassigned to new channels as part of the incentive auction and repacking process and have not yet completed the transition to their post-auction channels.

The freeze was originally imposed in light of the Spectrum Act which, among other things, gave the FCC authority to conduct an incentive auction and reorganize or "repack" the broadcast television bands in order to make additional licensed and unlicensed spectrum available for mobile broadband uses. To avoid frustrating the central goal of "repurpos[ing] the maximum amount of UHF band spectrum for flexible licensed and unlicensed use," the FCC found it necessary to limit the filing and processing of modification applications that would expand broadcast television stations' use of spectrum. Specifically, the FCC stopped accepting modification applications (or amendments to pending modification applications) by full power and Class A television broadcast licensees and permittees for changes to existing television service areas that would increase a full power station's noise-limited contour or a Class A station's protected contour in one or more directions beyond the area resulting from the station's present parameters as represented in its authorizations (license and/or construction permit). Similarly, the FCC stopped accepting Class A displacement applications that would increase the station's protected contour.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

FCC Announces Nationwide Test of Emergency Alert System on August 7, 2019

The FCC has scheduled the 2019 Emergency Alert System (EAS) nationwide test for Wednesday, August 7, 2019, at 2:20 p.m. EDT, with a backup date of August 21, 2019. All EAS Participants, including wired and wireless cable television systems, as well as wireline video systems, are required to participate in this test.

The EAS Test Reporting System (ETRS) is open for 2019 filings. If they have not done so already, our clients that are EAS Participants should renew their identifying information in the 2019 ETRS Form One to identify and make necessary updates to the information previously provided. All EAS Participants must renew their identifying information required by ETRS Form One on an annual basis.

In contrast to previous years, this year’s EAS test will not use the Internet to distribute the EAS message. Only the broadcast “daisy-chain” system will be used. It is therefore very important that clients review their state EAS plans to confirm they are monitoring the proper broadcast stations. Testing the daisy chain will allow the FCC and FEMA to assess the reliability and effectiveness of broadcast-based alerting as a failsafe to our national emergency communications infrastructure.

In preparation for the test, participants are encouraged to take the following steps:

• Confirm that a copy of the EAS Operating Handbook is located at normal duty positions, or EAS equipment locations, and is otherwise immediately available to operators;
• Review the EAS Operating Handbook for the actions to be taken by operators upon receipt of the test alert, and tailor any actions as necessary that are specific to the EAS Participants’ facilities;
• Review their State EAS Plan for monitoring assignments, and ensure that EAS equipment is accurately configured to monitor those sources;
• Confirm that EAS equipment can receive and process the NPT code, the “six zeroes” national location code, and otherwise operate in compliance with the Commission rules;
• Upgrade EAS equipment software and firmware to the most recent version; and
• Manually synchronize EAS equipment clocks to the official time provided by the National Institute of Standards and Technology, if an EAS Participant’s equipment does not automatically synchronize to an Internet time source.

Other compliance dates/deadlines that EAS Participants should mark on their calendars are as follows:

• EAS Participants must file the “day of test” information sought by ETRS Form Two on or before 11:59 p.m. EDT on Wednesday, August 7, 2019
• EAS Participants must file the detailed post-test data sought by ETRS Form Three on or before September 23, 2019.

ETRS Forms Two and Three will become available in the ETRS at the time of initiation of the 2019 nationwide test. Clients with any questions or who would like us to assist them in obtaining further information should contact the firm.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

Law & Regulation

Senate Reintroduces AIRWAVES Act

On July 23, Sens. Maggie Hassan, D-N.H., Catherine Cortez Masto, D-Nev., Tammy Baldwin, D-Wis., Cory Gardner, R-Colo., Marco Rubio, R-Fla., and Shelley Moore Capito, R-W.V., reintroduced the Advancing Innovation and Reinvigorating Widespread Access to Viable Electromagnetic Spectrum (AIRWAVES) Act. According to the bill’s sponsors, the bill will “encourage the Federal government to continue to free up spectrum for commercial licensed and unlicensed use and leverage the success of spectrum auctions to help close the urban-rural divide.”

The text of the bill is not yet available, but is likely the same as the 2018 bill. That version required the FCC to complete auctions during each of the next three calendar years that will grant new broadcast licenses for specified frequency spectrum bands. It also directed the FCC and the National Telecommunications and Information Administration to identify frequencies in specified spectrum bands that may be utilized for: (1) non-federal unlicensed use; and (2) commercial licensed use. Finally, it required the FCC to allocate 10% of proceeds from each of the spectrum band auctions specified in the bill to expand wireless infrastructure in rural areas that are underserved or unserved.

“The bipartisan AIRWAVES Act would free up badly-needed spectrum to help speed up the development of innovative 5G technologies and, crucially, it would also make meaningful investments in expanding rural broadband infrastructure in places like New Hampshire,” Hassan said.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

House Approves Robocall Bill

On July 17, the Stopping Bad Robocalls Act (H.R. 3375) was favorably reported, as amended, to the full House of Representatives by a vote of 48-0. Energy and Commerce Chairman Frank Pallone, Jr. (D-NJ) introduced the bill with Ranking Member Greg Walden (R-OR), Communications and Technology Subcommittee Chairman Mike Doyle (D-PA) and Communications and Technology Subcommittee Ranking Member Bob Latta (R-OH). As we reported in a previous edition of the BloostonLaw Telecom Update, H.R. 3375, the “Stopping Bad Robocalls Act,” would require the FCC to adopt certain consumer protections, require all carriers, over time, to implement call authentication technology, and to allow the blocking of calls in a reasonable manner without an extra charge, and more.

Several amendments were also adopted through voice vote. One amendment to H.R. 3375, offered by Pallone and Walden, makes technical changes to the bill and includes transparency and redress for erroneously blocked calls. Another amendment, offered by Reps. Debbie Dingell (D-MI) and Michael Burgess (R-TX), requires the FCC to establish a Hospital Robocall Working Group to, among other things, issue best practices to help voice service providers combat unlawful robocalls made to hospitals and to help hospitals protect themselves from robocalls. The amendment also requires the FCC to initiate a proceeding to determine whether the voluntary adoption of the practices can be facilitated. A third amendment, offered by Reps. Bill Flores (R-TX) and Jerry McNerney (D-CA), allows the FCC to assess an additional $10,000 penalty for a robocall violation if the offender acted with intent to cause the violation.

In a statement, Rep. Pallone said: “Today, the American people are one step closer to reclaiming control of their phones from annoying and illegal robocalls. I’m proud of the strong support the Stopping Bad Robocalls Act received in Committee today, and thank Ranking Members Walden and Latta and Chairman Doyle for working with me on this legislation to end the robocall epidemic. This legislation will ensure every call Americans get is verified by Caller ID and that consumers can block calls they don’t want. I look forward to having the full House vote on our bill soon.”

BloostonLaw Contacts: Mary Sisak and Sal Taillefer.

Antenna Height Rule Modifications Effective August 19

On July 19, the FCC published the Federal Register notice of the effective date of the rule revisions it made for fixed white space devices. These changes will become effective August 19.

Specifically, the FCC’s revisions require all fixed white space devices to incorporate a geo-location capability such as GPS and eliminate the option that permitted the geographic coordinates of a fixed device to be determined by a professional installer. The FCC also will allow the use of external geo-location sources by a fixed white space device when the device is used at a location where its internal geo-location capability does not function, such as deep inside a building. In addition, the FCC will require fixed white space devices to periodically re-check their geographic coordinates at least once a day and report the coordinates to the white space database. However, revisions to rule 95.2309, which covers WMTS frequency coordinate, will be effective at a later date.

BloostonLaw Contacts: John Prendergast.

FCC Issues $25,000 Forfeiture for Failing to Light Two Antenna Structures

On July 23, the FCC issued a Forfeiture Order imposing a penalty of $25,000 against Pentecostal Temple Development Corporation (Pentecostal Temple) for failing to properly light two antenna structures, for failing to notify the FAA of lighting extinguishments, and for failing to clean or repaint the antenna structures as often as necessary to maintain good visibility. The FCC also noted that the company engaged in “procedurally deficient shenanigans” rather than filing a proper response to FCC inquiry, but did not appear to adjust the forfeiture as a result.

Specifically, on December 30, 2016, the FCC issued a Notice of Apparent Liability for Forfeiture (Notice) proposing a $25,000 forfeiture against Pentecostal Temple for willful and repeated violation of section 303(q) of the Communications Act and sections 17.23, 17.48(a), and 17.50 of the Commission’s rules. On January 30, 2017, Pentecostal Temple submitted to the Office of Managing Director a Petition for Reconsideration of the Notice, and on February 21, 2017, it submitted to the Office of Managing Director a Response to the Notice. In both instances, Pentecostal Temple failed to send copies of either document to the FCC, as instructed in the Notice. On March 16, 2017, the Office of Managing Director returned both the Petition for Reconsideration and the Notice Response to Pentecostal Temple without processing, because Pentecostal Temple failed to comply with the written directions contained in the Notice.

BloostonLaw Contact: Richard Rubino

Industry

Jamie Susskind Leaves Commissioner Carr’s Office

On July 19, FCC Commissioner Brendan Carr announced that Jamie Susskind will leave the FCC. Ms. Susskind served as Commissioner Carr’s Chief of Staff and Legal Advisor for wireline and consumer issues. She will be replaced by Joseph Calascione as Acting Legal Advisor for wireline and consumer issues.

Prior to joining Commissioner Carr’s Office, Ms. Susskind served in senior roles on Capitol Hill, including as Chief Counsel to Senator Deb Fischer and on the staff of the Senate Commerce Committee under the leadership of then-Chairman John Thune. In those capacities, Ms. Susskind played lead roles in the passage of Kari’s Law and anti-spoofing legislation. Earlier in her career, Ms. Susskind worked for six years in the FCC’s Wireline Competition Bureau.

Prior to his appointment as Acting Legal Advisor to Commissioner Carr, Mr. Calascione worked at the Office of Economics and Analytics and Wireline Competition Bureau. In OEA, Mr. Calascione served as a special counsel and worked to get the new OEA up and running. Prior to that, he served as a legal advisor in the front office of the FCC’s Wireline Competition Bureau, where he worked on policies to accelerate wireline infrastructure deployment.

“I want to extend my deep gratitude and appreciation to Jamie for her years public service,” said Commissioner Carr. “Jamie was the first person I hired, and she’s played an invaluable role in nearly every one of the FCC’s achievements over the past two years.”

Deadlines

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: 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 1: Live 911 Call Data Reports: 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. Clients should obtain spreadsheets with their company’s compliance data from their E911 service provider (e.g., Intrado / West).

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 2019 is due to be filed August 29 at the Library of Congress’ Copyright Office by cable TV service providers.

BloostonLaw Contact: Gerry Duffy.

SEPTEMBER 3: FCC FORM 477, LOCAL COMPETITION AND BROADBAND REPORTING FORM. Normally due September 1, this year’s filing falls on a federal holiday weekend, pushing the deadline back to the next business day. Four 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 FCC 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. 24 – Comments are due on SHAKEN/STIR NPRM.
Jul. 29 – Comments are due on USF Cap NPRM.
Jul. 31 – Comments are due on Lifeline Minimum Service Standards Petition.
Jul. 31 – Carrier Identification Code (CIC) Report is due.

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 from Non-Nationwide Providers are due.
Aug. 5 – Comments are due on VRS Program FNPRM.
Aug. 5 – Reply comments are due on Leased Commercial Access NPRM.
Aug. 7 – Comments are due on 3.7-4.2 GHz Band Proposals.
Aug. 14 – Reply comments are due on 3.7-4.2 GHz Band Proposals.
Aug. 15 – Auction 103 Initial Commitment filings are due.
Aug. 15 – Reply comments are due on Lifeline Minimum Service Standards Petition.
Aug. 23 – Reply comments are due on SHAKEN/STIR NPRM.
Aug. 26 – Reply comments are due on USF Cap NPRM.

September
Sep. 3 – FCC Form 477 due (Local Competition and Broadband Report).
Sep. 9 – Short Form Application Deadline for Auction 103.
Sep. 30 – FCC Form 396-C (MVPD EEO Program Annual Report).

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Brad Dye
P.O. Box 266
Fairfield, IL 62837 USA

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• ex KN9IQY, KN4BK, KM5NK, WB4JCF, ZP5TQ, WA4VXU, WA9RVL, /TI2, /9Y4, /6Y5, /KP4, HH2FJ
• Licensed FCC Amateur Radio operator since 1957
• Licensed FCC First-Class-Commercial Operator/Engineer since 1964

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