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Friday — January 24, 2020 — Issue No. 892

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The Wireless Messaging News

Frontier issues statement in wake of report that it's planning bankruptcy

by Steven Baublitz
Jan 21, 2020

CLARKSBURG — A Frontier official responded Tuesday to recent reports that the company is planning to file bankruptcy in March.

Javier Mendoza, Frontier vice president of corporate communications and external affairs, said serving customers remains the No. 1 focus.

“Frontier’s business and operations are solid, and serving our customers remains our top priority. As we have said publicly, Frontier is evaluating its capital structure with an eye to reducing debt so as to be able to better serve our customers. Our customers should expect no changes as we remain focused on providing connectivity services without interruption to our residential customers, institutions and businesses. We are proud to continue to offer well-paying jobs and benefits that contribute to the economic health of the communities we serve,” Mendoza said.

Frontier, the provider of telecom services in 29 states, including West Virginia, has $356 million in debt payments due by March 15, and in September 2019, the company was reported to have $16 billion in debt. The company has struggled as the telecommunications industry has evolved.

As of yet, Frontier has not officially declared bankruptcy.

Much of its financial problems, according to ARS Technica, stem from loss of customers because of service issues.

Frontier reported a loss of about 350,000 customers in a 12-month period ending in September 2019, as well as drop of about 2,000 employees.

Marion County Commissioner Randy Elliot said he is aware that residents in Marion, as well as other counties, have been affected by the deteriorating service from Frontier.

“Some counties are in worse shape with lines, (service) quality and integrity of equipment. ... I will make this clear: I don’t like the fact our citizens are paying for and not getting the quality of services of Internet and phone they are paying for,” he said.

While he is unsure of what the company’s next steps will be at this time, Elliot said the issues need to be corrected sooner rather than later.

“We need to do (ensure) citizens of West Virginia and neighboring counties are provided with the services they are paying for,” he said.

If that means “holding Frontier’s feet to the fire,” he added, then that is what should be done and a more capable provider should be allowed the opportunity to correct it. [source]

Wireless Messaging News

  • Emergency Radio Communications
  • Wireless Messaging
  • Critical Messaging
  • Two-way Radio
  • Technology
  • Telemetry
  • Science
  • Paging
  • Wi-Fi
wireless logo medium


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.

About Us

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.

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.

I spend the whole week searching the Internet for news that I think may be of interest to you — so you won’t have to. This newsletter is an aggregator — a service that aggregates news from other news sources. You can help our community by sharing any interesting news that you find.

Editorial Policy

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.

We need your help. This is the only remaining news source dedicated to information about Paging and Wireless Messaging.

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Advertiser Index

IWA Technical Services, Inc.  (Ira Wiesenfeld)
Leavitt Communications  (Phil Leavitt)
Media 1
Prism Paging  (Jim Nelson & John Bishop)
Paging & Wireless Network Planners LLC  (Ron Mercer)
Wex International Limited

Service Monitors and Frequency Standards for Sale

Motorola Service Monitor

IFR Service Monitor

Efratom Rubidium Standard

(Images are typical units, not actual photos of items offered for sale here.)

Qty Item Notes
2 Late IFR 500As with new batteries
1 Motorola R 2001D  
4 Motorola R 2400 and 2410A  
5 Motorola R 2600 and R 2660 late S/Ns  
4 Motorola R 1200  
2 Motorola R 2200  
2 Stand-alone Efratom Rubidium Frequency Standards 10 MHz output
1 Telawave model 44 wattmeter Recently calibrated
1 IFR 1000S  
All sold with 7 day ROR (Right of Refusal), recent calibration, operation manual and accessories  
Factory carrying cases for each with calibration certificate  
Many parts and accessories  

Frank Moorman animated left arrow

(254) 596-1124

Leavitt Communications


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

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Contact us for price and availability please

Philip C. Leavitt
Leavitt Communications
7508 N. Red Ledge Drive
Paradise Valley, AZ 85253
Web Site:
Mobile phone: 847-494-0000
Telephone: 847-955-0511
Fax: 270-447-1909
Skype ID: pcleavitt


Hong Kong


W8001 (4 Line/8 Line IP67 Alphanumeric Pager)

W8008 Thinnest IP67 Rated Alphanumeric Pager 4 Line/8 Line, OLED Display

W2028 (2 Line/4 Line Alphanumeric Pager)

For Trade inquiries contact:
Eric Dilip Kumar

  • Available in VHF, UHF & 900 MHz Full Range Frequency Bands
  • We are OEM for Major Brand names in USA and Europe
  • We also Design and Manufacture POCSAG Decoder Boards
  • We can Design and Manufacture to customer specifications
  • Factory located in Shenzhen, China
  • Pagers have FCC, RoHs, C-Tick, CE-EMC, IC Approvals

Visit our websites for more details

For ESPAÑOL, PORTUGUÊS AND DEUTSCH versions, please go to:

Southern Illinois Internet provider Frontier Communications expected to declare bankruptcy

Gabriel Neely-Streit Jan 22, 2020 Updated Jan 22, 2020

Hundreds of fiber optic (left) and older copper (right) cables providing Internet and telephone service run from the Frontier Communications building in Carbondale out to various areas of the city. Byron Hetzler

CARBONDALE — Frontier Communications, an Internet service provider with significant presence in Southern Illinois, appears poised to declare Chapter 11 bankruptcy, Bloomberg reported last week, after a private meeting between Chief Executive Officer Bernie Han and some of Frontier’s major creditors.

Frontier, which offers residential and business services across 29 states, has steadily lost customers over the last year, down about 8.2% in residential clients to 3.81 million and down about 9.7% in business clients, to 381,000 as of Sept 2019, according to technology news outlet Ars Technica.

Company leaders have publicly acknowledged Frontier seeks to lessen its debt load, but have not confirmed bankruptcy reports.

“Frontier is evaluating its capital structure with an eye to reducing debt and interest expense so as to be able to better serve our customers. Our customers should expect no changes as we remain focused on providing quality communications services,” said Javier Mendoza, Frontier’s vice president of corporate communications and external affairs.

While most towns along Illinois 13, U.S. 51 and Interstate 57 may choose between Frontier and Mediacom for residential Internet service, much of rural Southern Illinois is only served by Frontier, according to BroadbandNow, a company that gathers Federal Communications Commission and National Telecommunications and Information Administration data to help consumers make informed decisions.

Frontier declined to provide any information to The Southern Illinoisan about its Southern Illinois client base.

Most rural Southern Illinois residents receive Internet speeds far below the national average for broadband Digital Subscriber Line (DSL) Internet, which travels on copper phone lines, BroadbandNow has found.

In Makanda, the average download speed is 7.9 Mbps, BroadbandNow speed tests show, meaning customers pay about $3.65 per megabit of download speed received. In Chicago, by comparison, the average download speed is 59.9 Mbps, and the average consumer cost per megabit is about $0.40.

Nationwide, average download speed is 52.1 mbps.

About 40% of Americans have access to only one Internet service provider, according to a study by the Institute for Local Self Reliance, featured by Vice News.

Source: The Southern Illinoisan  

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.
  • Healthcare Paging systems.
  • Public Safety Emergency Services Paging systems.
  • 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.

Prism-IPX Systems LLC.

11175 Cicero Dr., Alpharetta, GA 30022
Ph: 678-242-5290 Email:

  • LIVE response possible to any program with Media 1 Live app from Android or Apple stores, summed up immediately for producer on web site
  • Propose LIVE broadcast on Internet with live response to reach youth with low cost quality education, seeking persons interested.
  • Contact:


“Is Paging Going Away?” by Jim Nelson

  • Click here for English.
  • Click here for German. (Berlin Revision: November 8, 2016)
  • Click here for French.

Here is an English PDF edit of this paper formatted with page breaks and suitable for printing.

Volunteers needed for translations into other languages.


Board of Advisors

The Wireless Messaging News
Board of Advisors

Frank McNeill
Founder & CEO
Communications Specialists
Jim Nelson
President & CEO
Prism Systems International
Kevin D. McFarland, MSCIS
Sr. Application Systems Analyst
Medical Center
Paul Lauttamus, President
Lauttamus Communications & Security
R.H. (Ron) Mercer
Wireless Consultant
Barry Kanne
Paging Industry Veteran
Ira Wiesenfeld, P.E.
Consulting Engineer
Allan Angus
Consulting Engineer

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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Newspapers generally cost 75¢ $1.50 a copy and they hardly ever mention paging or wireless messaging, unless in a negative way. If you receive some benefit from this publication maybe you would like to help support it financially?

A donation of $50.00 would certainly help cover a one-year period. If you are wiling and able, please click on the PayPal Donate button above.

St. Louis Smart City Project Integrates Public-Safety Applications

Friday, January 17, 2020

The Department of Homeland Security (DHS) Science and Technology Directorate (S&T) conducted its final integration of smart city technologies this week in St. Louis in collaboration with the city, the Open Geospatial Consortium (OGC) and the T-REX Innovation Center (T-REX).

After an initial pilot kickoff in August, DHS S&T and its partners continued to work with the city to use Smart City Interoperability Reference Architecture (SCIRA) as an inter-operable framework, integrating commercial proprietary Internet of things (IoT) sensors for public-safety applications and assessing open standards. This final rollout event, which included a series of tabletop exercises and operational scenarios, demonstrated how the technologies could be leveraged by first responders, emergency managers and other city officials in real-life events, such as floods, fires or earthquakes.

The intended outcomes of this smart city effort were to enhance overall public safety, streamline efficient, effective operations across all city departments and validate the SCIRA architecture for adoption by future smart city efforts.

“With this experiment, and by bringing in a variety of city, federal and other stakeholders, we are aiming to get cities to prioritize their procurement and have a clear vision of their immediate operational needs and desired benefits in a realistic manner,” Norman Speicher, S&T program manager said.

The demonstration took place at T-REX, a non-profit technology innovation and entrepreneur development center in downtown St. Louis.

“The OGC team of participating global vendors is excited to engage in this exercise by contributing their state-of-the-art inter-operable products and documenting the interoperability testing in reusable deployment guides,” said Nadine Alameda, the CEO of OGC. “This collaborative exercise is the most effective way to validate the standards-based architecture and ensure other cities have a tested framework to acquire and deploy their own smart city technologies in a cost effective and future-proof way.”

Source: Radio Resource International  

Prism-IPX Systems

prism-ipx systems

prism-ipx systems
prism-ipx systems


prism-ipx systems


Click on the image above for more info about advertising here.

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.

Input Protocols: Serial and IP
Output Protocols: Serial and IP
FLEX (optional PURC control)   POCSAG (optional PURC control)

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.

11175 Cicero Dr., Alpharetta, GA 30022
Ph: 678-242-5290 e-mail:

South Carolina Sales Tax on Cloud Based Services

Embed Burr & Forman
January 22, 2020

South Carolina imposes sales tax on retail sales of tangible personal property. South Carolina generally does not impose a sales tax on intangible property, however, certain intangible property is deemed to be tangible personal property that is subject to sales tax. Deemed tangible personal property includes charges for communications. South Carolina defines charges for communications to include the proceeds accruing from the charges for the ways or means for the transmission of the voice or messages. The South Carolina Department of Revenue (DOR) takes the position charges for the ways or means of communication include charges for access to, or use of, a communication system. Examples of communication services that have been found to be taxable include telephone services, paging services, answering services, cable television services, streaming services, satellite television, satellite radio, e-mail services, and database access transmission services (e.g. legal research services, credit reporting services, and charges to access a website).

In the context of cloud based services, DOR has issued guidance finding charges by an Application Service Provider are subject to sales tax as charges for the ways or means of for access to a communication system. An Application Service Provider is a company that provides customers access or use of software on the company’s website. An Application Service Provider is essentially equivalent to the more commonly used term Software as a Service (SaaS). The SaaS model allows a customer to access a company’s applications on the company’s infrastructure.

DOR recently issued a private letter ruling, SC Private Letter Ruling #20-1, which determined that charges for cloud-based software that collects and stores customers’ billing and revenue data and provides inventory management and reporting analytics were subject to sales tax. The software was billed on a monthly subscription basis. While the software manipulated data, the company itself did not manipulate any of the data (there is a South Carolina sales tax exemption for data processing). This guidance is a relatively straight-forward extension of DOR’s position regarding Application Service Providers (i.e. SaaS).

DOR has not issued specific guidance addressing Platform as a Service (PaaS) or Infrastructure as a Service (IaaS). The PaaS model allows a customer to utilize its software on a company’s cloud infrastructure in an environment provided by the company. The IaaS model allows a customer to utilize a company’s cloud infrastructure to run the customer’s software in a configuration determined by the customer.

The taxability of charges for PaaS and IaaS services is unclear. If DOR were to assert the charges are for the ways or means of communication then South Carolina sales tax would apply to charges for the services. If the services were instead characterized as charges for software (which is generally not subject to sales tax if electronically delivered) then South Carolina sales tax should not apply. If the charges were considered to be the equivalent of charges for the use of tangible personal property (i.e. the underlying cloud hardware) then South Carolina sales tax would not apply unless the use of the hardware is sourced to South Carolina instead of the location of the hardware.

Out-of-state cloud providers may not have been concerned with South Carolina sales tax in the past if they did not have a physical presence in South Carolina. Out-of-state cloud providers which are now obligated to collect South Carolina sales tax because they have economic nexus (generally sales of $100,000 or more in a year) must now grapple with the uncertain applicability of South Carolina sales tax to certain cloud based services. Depending on the circumstances, cloud providers and their customers may need to review their contractual relationships and so as not to trigger an unintended South Carolina sales tax obligation.

Source: JDSupra (emphasis added)

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:

Wireless Network Planners

Wireless Network Planners
Wireless Specialists

R.H. (Ron) Mercer
217 First Street
East Northport, NY 11731

ron mercer
Telephone: 631-786-9359 left arrow left arrow

Dutch Limburg-Noord security region grants contract to pagers

Wednesday 22 January 2020 | 13:23 CET | News

P2000 Alarm systems from Bergeijk in the Netherlands has won the pagers and monitoring tender for the Limburg-Noord security region, reported. Three parties signed up for the contract, which is worth about EUR 600,000. The winning party will have to deliver 800 alarm receivers with the ability to report back, 400 alarm receivers without that ability, 35 screens and a 10 programming sets.

Source: telecompaper  

Consulting Alliance

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 left arrow 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

Consulting Alliance

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


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:

Local fire departments awarded grants from the State Fire Commissioner’s Office

Posted: Jan 21, 2020 / 02:24 PM EST / Updated: Jan 21, 2020 / 02:24 PM EST

The State Fire Commissioner’s Office will grant more than $144,000 to 12 area emergency departments.

The grant money is used to maintain and improve facilities, as well as go towards equipment, training, and other costs associated to the departments.

One of the departments selected was Millcreek’s West Ridge Fire Department. West Ridge received $14, 248.03.

Fire Chief Jerry Derosa says the funding will go towards purchasing digital papers for active members, which costs about $500 per pager. Derosa says this will be a great time to help the department.

Derosa adds, “Which will enable our members to hear both sides of dispatch as well as equipment going in route, canceled, officers going in route — which we do not have that capability now, that we don’t have with analog pagers.”

Chief Derosa hopes to purchase 25 digital pagers.

Source: Your Erie  

Leavitt Communications

We can supply alphanumeric display, numeric display, and voice pagers.

We also offer NEW and refurbished Alphamate 250s, refurbished Alphamate IIs, the original Alphamate refurbished, and new and refurbished pagers, pager repairs, pager parts, and accessories. We are FULL SERVICE in Paging! Outstanding service is our goal.

E-mail Phil Leavitt ( ) for pricing and delivery information, or for a list of other available paging and two-way related equipment.

Phil Leavitt

7508 N. Red Ledge Drive
Paradise Valley, AZ 85253

Friday, January 24, 2020 Volume 8 | Issue 15


Torn American Flag Gets A Makeover From Crown

Before and after photo, taken 1/23/20, of the tower flag in Towamensing Township, PA. Second photo courtesy of Crown Castle.

Outside a volunteer fire company in Towamensing Township, PA a cell tower had the residents up in arms. Not over the tower, but what’s attached to it: a ripped and tattered American flag. BRCTV reported the sight was displeasing to residents and a “slap in the face” to veterans.

All eyes turned to tower owner Crown Castle to remedy the matter and, as of yesterday morning, a new “Old Glory” is flying over Towamensing. Crown brought in a special crane for the repair Thursday morning with due apologies to residents and assurances it will be monitored more closely in the future. The problem, according to Crown Castle Director of Public Relations Andrea Bradford, was that the tower was not an ideal structure for a flag and has sharp bolts on the pole that caused the unnaturally fast tearing.

“We have tried rubber caps, which fell off,” Bradford told Inside Towers, "and then a rubber solution that still did not prevent the bolts from ripping the flag. We were certainly alarmed by the condition of the flag when we were notified and share our respect for it and feel it’s our patriotic duty to keep it in good condition,” she said. Until a more permanent solution is found to mitigate the bolt problem, Bradford said Crown will keep a closer eye on it.

Source: Inside Towers newsletter Courtesy of the editor of Inside Towers Jim Fryer.
Inside Towers is a daily newsletter by subscription.

BloostonLaw Newsletter

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.

 BloostonLaw Telecom Update Vol. 23, No. 4 January 22, 2020 

Flurry of Last-Minute Proposals for Changes in Rural Digital Opportunity Fund Auction Order

At its January 30 Open Meeting, the FCC is scheduled to consider an order that would establish a pair of reverse auctions to award approximately $20.4 billion in High Cost Fund support over a ten-year term to deploy at least 25/3 Megabits per second (Mbps) broadband service predominately in areas where price cap carriers are currently receiving model-based support to construct 10/1 Mbps facilities under the CAF Phase II mechanism.

A draft Rural Digital Opportunity Fund (RDOF) order was circulated on January 9. It will adopt a nationwide, multi-round reverse auction very much like the CAF Phase II reverse auction that was conducted during the Summer of 2018 and that resulted in approximately two-thirds to three-fourths of the awarded support going to fixed wireless and satellite service providers. The draft order will auction off census block groups without 25/3 Mbps service (rather than smaller census blocks); and establishes four weighted speed tiers [25/3 Mbps (least favorable weight), 50/5 Mbps, 100/20 Mbps and 1 Gigabit/500 Mbps (most favorable weight)] and two weighted latency tiers [100 milliseconds or better (favored weight) and 750 milliseconds or better (disfavored weight)].

The FCC rejected advice to wait until improved broadband mapping could more accurately identify areas needing high cost support and until it could be determined whether the “winners” of the 2018 CAF Phase II reverse auction are actually able to deploy and deliver the broadband services that they promised with the reduced levels of high cost support they accepted.

Much of the eleventh-hour lobbying entails efforts by wireline and wireless/satellite entities to reduce what they perceive to be unfavorable tilts of the auction playing field. The wireless carriers are opposing a provision that would stop the auction once the aggregate bid support was less than the designated total budget (known as the “clearing round”) and award each area to the competing bidder with the most favorable combined speed-latency rate. The wireless carriers claim that this would unduly favor fiber optic proposals for 100/20 Mbps and Gigabit services, while wireline carriers claim that fiber optic networks are more scalable and better able technically and economically to respond to changing broadband needs over the next 10 years. Wireline carriers have raised questions regarding the equity and value of the 50/5 Mbps speed tier that was added by the FCC at the behest of a heavily wireless coalition. Meanwhile, satellite service providers are seeking changes in the latency weights and other provisions relating to voice services.

The other major area of last-minute contention is the irrevocable standby Letter of Credit that the draft order requires RDOF auction winners to provide. The FCC is convinced that it needs such Letters of Credit in order to recover high-cost support that it has distributed to RDOF auction “winners” that ultimately default on their broadband build-out obligations. Many entities, and particularly smaller ones, have complained that irrevocable Letters of Credit are extremely expensive, if available at all, and will eat up much of the high-cost support obtained during the RDOF auction. There are proposals circulating that would at least reduce the amount of the required Letter of Credit as the required broadband networks are deployed.

The FCC will consider the RDOF order, possible with some revisions of the January 9 draft, at its January 30 Open Meeting. It is expected that the first of the two RDOF reverse auctions will be scheduled for later this year.

We will keep you apprised of developments, and be available to assist clients that wish to participate in the RDOF auctions.

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


Second Round of ReConnect Grant/Loan Program Opens January 31

On December 12, 2019, the U.S. Secretary of Agriculture announced the availability of a second round of funding under the ReConnect Program. Applications for this new round of funding will be accepted beginning January 31, 2020. All applications will be due no later than March 16, 2020.

The Broadband ReConnect Program furnishes loans and grants to provide funds for the costs of construction, improvement, or acquisition of facilities and equipment needed to provide broadband service in eligible rural areas. USDA will make up to $200 million for grants, up to $200 million for 50/50 grant/loan combinations, and up to $200 million for low-interest loans.

  • The entities considered eligible to apply for assistance under the ReConnect Program include: cooperatives, non-profits, or mutual associations; for-profit corporations or limited liability companies; and states and local governments.
  • Award Funds may be used to fund the construction or improvement of buildings, land, and other facilities that are required to provide broadband service; reasonable pre-application expenses; the acquisition and improvement of an existing system that is currently providing insufficient broadband service (eligible for 100 percent loan requests only); and/or terrestrial-based facilities that support the provision of satellite broadband service.
  • Award amounts under this announcement will be limited as follows: up to $200,000,000 is available for grants (maximum $25,000,0000 per application); up to $200,000,000 is available for loan/grant combinations (maximum $25,000,000 grand and $25,000,000 loan per application); and up to $200,000,000 is available for loans (maximum $50,000,000 per application).

During the first round of funding, the application windows were open between April 23, 2019 and July 12, 2019. USDA received 146 applications requesting $1.4 billion in funding across all three ReConnect Program funding products: 100 percent loan, 100 percent grant, and loan-grant combinations. USDA is currently reviewing applications and announcing approved projects on a rolling basis.

Carriers interested in applying for ReConnect funding should contact the firm for more information.

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

Law and Regulation

Comments on Vertical Location Accuracy Due February 18

On January 16, the FCC issued a Public Notice announcing that its Fifth Report and Order and Fifth Further Notice of Proposed Rulemaking (R&O and FNPRM, PS Docket No. 07-114) adopting rules for transmitting vertical, or “z-axis,” location information with indoor wireless 911 calls and seeking comment on narrowing the z-axis location accuracy metric was published in the Federal Register. Accordingly, the rules adopted in the R&O will take effect on March 16, 2020, with the exception of rules containing information collection requirements that must be approved by the OMB under the Paperwork Reduction Act (PRA). Comments pertaining to the FNPRM must be filed on or before February 18, 2020, and reply comments must be filed on or before March 16, 2020.

Specifically, the FCC adopted a 3-meter z-axis 911 location accuracy metric to be implemented by the April 2021 and 2023 vertical accuracy deadlines. Given the likelihood that vertical location technology will continue to improve, the FCC also sought comment on whether to establish a long-term timeline for migrating to a more stringent z-axis metric than 3 meters, and ultimately whether to require CMRS providers carriers to deliver floor level information in conjunction with wireless indoor 911 calls. The FCC also proposed to amend the rules to expand on the current options for demonstrating deployment of z-axis or dispatchable location capability.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

Comments on Removing Radiolocation/Amateur Allocations in the 3.3-3.55 GHz Band

On January 22, the FCC published in the Federal Register its Notice of Proposed Rulemaking (NPRM) proposing to remove the existing non-federal secondary radiolocation and amateur allocations in the 3.3-3.55 GHz band and to relocate incumbent non-federal operations out of the band, in order to prepare the band for possible expanded commercial wireless use. Interested parties may file comments on or before February 21, 2020; and reply comments on or before March 23, 2020.

Specifically, the NPRM would eliminate the non-federal radiolocation services allocation in the 3.3-3.55 GHz band and the non-federal amateur allocation in the 3.3-3.5 GHz band. This NPRM also seeks comment on appropriate relocation options for incumbent non-federal users, either to the 3.1-3.3 GHz band or to other frequencies, on the transition mechanism and process for relocating existing non-federal users, and on potential relocation costs and considerations. The proposals in the NPRM are an initial step toward potential future shared use between federal operations and flexible use commercial services, consistent with the Commission's responsibilities specified in the MOBILE NOW Act to identify spectrum for new mobile and fixed wireless use and to work in consultation with the National Telecommunications and Information Administration (NTIA) to evaluate the feasibility of allowing commercial wireless services to share use of spectrum between 3.1 and 3.55 GHz.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.


FCC Updates CSRIC Database

On January 15, the FCC issued a Public Notice announcing that it has updated the Communications Security, Reliability, and Interoperability Council (CSRIC) Best Practices database. At its December 10, 2019, quarterly meeting, CSRIC VII unanimously approved an update to the database that includes best practices from CSRIC VI (addressing communications network security, emergency preparedness, and disaster recovery) and retires best practices that have become obsolete.

When CSRIC recommends new best practices, the FCC updates the database accordingly, including the retiring of any older best practices that have been superseded. The CSRIC Best Practices database can be accessed on the FCC website at More information about CSRIC can be found at


FEBRUARY 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 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 499-A that is due April 1.

BloostonLaw Contacts: Ben Dickens, Gerry Duffy, and Mary Sisak.

FEBRUARY 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 February 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 are required to include their FCC Registration Number (FRN). Reporting carriers file utilization and forecast reports semiannually on or before February 1 for the preceding six-month reporting period ending December 31, and on or before August 1 for the preceding six-month reporting period ending June 30.

BloostonLaw Contacts: Ben Dickens, Gerry Duffy, and Mary Sisak.

FEBRUARY 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.

MARCH 1: COPYRIGHT STATEMENT OF ACCOUNT FORM FOR CABLE COMPANIES. This form, plus royalty payment for the second half of calendar year 2019, is due March 1. The form covers the period July 1 to December 31, 2019, and is due to be mailed directly to cable TV operators by the Library of Congress’ Copyright Office. If you do not receive the form, please contact the firm. BloostonLaw Contact: Gerry Duffy. MARCH 1: CPNI ANNUAL CERTIFICATION. Carriers should modify (as necessary) and complete their “Annual Certification of CPNI Compliance” for 2020. The certification must be filed with the FCC by March 1. Note that the annual certification should include the following three required Exhibits: (a) a detailed Statement Explaining How The Company’s Operating Procedures Ensure Compliance With The FCC’S CPNI Rules to reflect the Company’s policies and information; (b) a Statement of Actions Taken Against Data Brokers; and (c) a Summary of Customer Complaints Regarding Unauthorized Release of CPNI. A company officer with personal knowledge that the company has established operating procedures adequate to ensure compliance with the rules must execute the Certification, place a copy of the Certification and accompanying Exhibits in the Company’s CPNI Compliance Records, and file the certification with the FCC in the correct fashion. Our clients can forward the original to BloostonLaw in time for the firm to make the filing with the FCC by March 1, if desired. BloostonLaw is prepared to help our clients meet this requirement, which we expect will be strictly enforced, by assisting with preparation of their certification filing; reviewing the filing to make sure that the required showings are made; filing the certification with the FCC, and obtaining a proof-of-filing copy for your records. Clients interested in obtaining BloostonLaw's CPNI compliance manual should contact the firm.

BloostonLaw Contact: Gerry Duffy

MARCH 1: FCC FORM 477, LOCAL COMPETITION & BROADBAND REPORTING FORM. This annual form is due March 1 and September 1 annually. The FCC requires facilities-based wired, terrestrial fixed wireless, and satellite broadband service providers to report on FCC Form 477 the number of broadband subscribers they have in each census tract they serve. The Census Bureau changed the boundaries of some census tracts as part of the 2010 Census. Specifically, 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, BRS 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 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.

Law Offices Of
Blooston, Mordkofsky, Dickens,
Duffy & Prendergast, LLP

2120 L St. NW, Suite 300
Washington, D.C. 20037
(202) 659-0830
(202) 828-5568 (fax)


Harold Mordkofsky, 202-828-5520,
Benjamin H. Dickens, Jr., 202-828-5510,
Gerard J. Duffy, 202-828-5528,
John A. Prendergast, 202-828-5540,
Richard D. Rubino, 202-828-5519,
Mary J. Sisak, 202-828-5554,
D. Cary Mitchell, 202-828-5538,
Salvatore Taillefer, Jr., 202-828-5562,

This newsletter is not intended to provide legal advice. Those interested in more information should contact the firm.

Calendar At-a-Glance

Jan. 27 – Comments are due on Lifeline Reforms.
Jan. 27 – Comments are due on Consent Requirements for Wireless Carrier Marketing Messages.
Jan. 29 – Comments are due on Robocall Blocking Report.
Jan. 31 – FCC Form 555 (Annual Lifeline ETC Certification Form) is due.

Feb. 1 – FCC Form 499-Q (Quarterly Telecommunications Reporting Worksheet) is due.
Feb. 1 – FCC Form 502 (Number Utilization and Forecast Report) is due.
Feb. 1 – Live 911 Call Data Reports from Non-Nationwide Providers are due.
Feb. 3 – Comments on Supply Chain Prohibitions FNPRM are due.
Feb. 3 – Comments on Initial Designations of Huawei and ZTE under Supply Chain Prohibitions due.
Feb. 6 – Comments are due on Cable Service Charge Notification NPRM.
Feb. 11 – Reply comments are due on Consent Requirements for Wireless Carrier Marketing Messages. Feb. 12 – Comments are due on Truth-in-Billing for VoIP proceeding.
Feb. 18 – Comments are due on Vertical Location Accuracy.
Feb. 21 – Comments are due on Removing Radiolocation/Amateur Allocations in 3.3-3.5 GHz Band.
Feb. 25 – Reply comments are due on Lifeline Reforms.
Feb. 21 – Reply comments are due on Cable Service Charge Notification NPRM.
Feb. 28 – Reply comments are due on Robocall Blocking Report.

Mar. 1 – Copyright Statement of Account Form for cable companies is due.
Mar. 1 – Annual CPNI Certification is due.
Mar. 1 – FCC Form 477 (Local Competition & Broadband Reporting) is due.
Mar. 3 – Reply comments on Supply Chain Prohibitions FNPRM are due.
Mar. 9 – Comments are due on All-Digital AM Broadcasting NPRM.
Mar. 13 – Reply comments are due on Truth-in-Billing for VoIP proceeding.
Mar. 16 – Reply comments are due on Vertical Location Accuracy.
Mar. 23 – Reply comments are due on Removing Radiolocation/Amateur Allocations in 3.3-3.5 GHz Band. Mar. 31 – FCC Form 525 (Delayed Phasedown CETC Line Counts) is due.
Mar. 31 – FCC Form 508 (ICLS Projected Annual Common Line Requirement) is due.

Apr. 6 – Reply comments are due on All-Digital AM Broadcasting NPRM.

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“I love Paris”

Avalon Jazz Band — “I love Paris” (Cole Porter)


I love Paris in the spring time
I love Paris in the fall I
love Paris in the winter when it drizzles
I love Paris in the summer when it sizzles

I love Paris every moment
Every moment of the year
I love Paris, why, oh why do I love Paris
Because my love is here

I love Paris every moment
Every moment of the year
I love Paris, why, oh why do I love Paris
Because my love is here

“I Love Paris” was written by Cole Porter in 1953.

Source: YouTube  

Best regards,
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