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Messaging News

This Week's Wireless News Headlines

• Space Data Spectrum Sales Ascend To The Stratosphere
• Satellite antennas could be 3D printed in space to massively reduce launch costs
• Out Of Order Apple warning: Millions of iPhone owners warned about bizarre iMessage bug that BLOCKS your texts
• Generator Used To Alert Volunteer Firefighters Of Emergencies Stolen In Douro-Dummer, Canada
• Your iPhone, iPad and Mac have a secret setting to massively boost call quality
• FCC To Consider Franken-FM Status and Whether To Expand Radio Service On Channel 6
• Knowing Your Place: The Implications of GPS Spoofing and Jamming
• EDITORIAL
  • Emergency Digital Paging over Public Television
• INSIDE TOWERS
  • View From the Top Panel Discusses Strengths, Weaknesses of Towers
• BLOOSTONLAW TELECOM UPDATE
  • REMINDER: Form 481 Filing System Now Open; July 1 Filing Deadline Temporarily Waived
  • NTIA Announces Broadband Funding Opportunity of $41.6 Billion
  • FCC Announces Tentative Agenda for June Open Meeting
  • Comments on Certified Professional Engineer Requirement for Broadband Data Maps Due June 8
  • FCC Opens Docket on DISH AWS Buildout Compliance
  • Comments on Wireless Emergency Alert FNPRM due June 21
  • Comment Sought on Video Content Vendor Diversity Report Petition
  • NTIA Announces 34 States and Territories Have Signed Up for BEAD
  • Deadlines
• BloostonLaw Contacts
• Calendar At-a-Glance
• Who Is BloostonLaw?
• TECHNICIAN'S CORNER
• Bursted noise on my bench from my under-shelf lighting strip!
• THIS WEEK'S MUSIC VIDEO
  • “The Real Revolution”
  • Playing For Change Band

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.

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 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.

Click on the image above for more info about advertising in this newsletter.

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There is not a lot of news about Paging these days but when anything significant comes out, you will probably see it here. I also cover text messaging to other devices and various articles about related technology.

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Advertiser Index

Service Monitors and Frequency Standards for Sale

Motorola Service Monitor

IFR Service Monitor

IFR 500A Service Monitor

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

2535 West Fairview Street Suite 101 Chandler, AZ 85224 (480) 722-2100

SPACE DATA SPECTRUM SALES ASCEND TO THE STRATOSPHERE

CHANDLER, AZ May 16, 2022 — Space Data Corporation, the largest holder of Narrowband Personal Communication Services (NPCS) licenses across the United States, has recently filed with the Federal Communications Commission (FCC) to assign licenses to East River Electric Power Cooperative and The WEC Energy Group. Additionally, in recent months it has supplied AWS spectrum to Verizon in Alaska and Tampnet in the Gulf of Mexico.

The FCC has allocated three bands of 1 MHz each at 901, 930 and 940 MHz to NPCS. NPCS was originally used for 1 way paging and 2 way messaging. Space Data has assembled a nationwide holding of 1.8 MHz of NPCS licenses that aggregates adjacent channels into wider bandwidths allowing new uses for the spectrum. This has allowed the NPCS spectrum to be re-purposed for Advanced Metering, Internet of Things (IoT) and Field Area Networks (FANs). The spectrum is now being used by oil and gas companies and over a dozen utilities for FANs, as well as by advance metering infrastructure providers like Sensus, a division of Xylem, Inc.

East River Electric is a power supply cooperative that delivers wholesale power to 24 rural electric delivery cooperatives and one municipal system in eastern South Dakota and western Minnesota. Space Data is transferring 1.7 MHz of NPCS licenses to East River Electric in and around its service territory.

The WEC Energy Group subsidiaries provide energy services to more than 4.6 million customers in Wisconsin, Illinois, Michigan, and Minnesota. Space Data is transferring over 1 MHz of licenses to The WEC Group in and around Chicago for its Peoples Gas and North Shore Gas companies, in Wisconsin for its We Energies and Wisconsin Public Service electric and gas operations as well as in the upper peninsula of Michigan for its Upper Michigan Energy Resources electric and gas operations.

Space Data also has recently sold three Advanced Wireless Services (AWS) licenses. Verizon has completed purchase of the 20 MHz license in Northern Alaska. Tampnet is purchasing two Gulf of Mexico AWS licenses for its cellular network servicing the petrochemical industry’s offshore operations from sites on oil and gas rigs. In each of these transfers, Space Data is leasing back a remote portion of the licenses for future stratospheric operations.

Space Data is the leader in stratospheric communications platforms. Our SkySites™ Platforms operate at altitudes 2 to 3 times higher than commercial airliners. Space Data holds its NPCS licenses within its Space Data Spectrum Holdings LLC and Space Data Radio LLC subsidiaries. Space Data utilizes its NPCS licenses to reach across all 50 US States and US territories. Space Data also supplies its SkySat™ Platforms to all four branches of the military and other government agencies, which operate them on government spectrum. For more information see www.spacedata.net.

Contact:
Jim Wiesenberg
Chief Strategy Officer
602.690.4929 or
jwiesenberg@spacedata.net

50 years experience providing and supporting radio and paging customers worldwide. Call us anytime we can be useful!

			Minitor VI
Leavitt sells and supports most pager brands. We stock Unication G1, G5, Secure and some Elegant pagers. Call or e-mail for price and availability.

INNOVATION

Satellite antennas could be 3D printed in space to massively reduce launch costs

'Additive-manufacturing in space has now become possible.'

Chris Young By Chris Young May 23, 202

Mitsubishi

A new in-orbit implementation of 3D printing technology could significantly reduce the costs of satellite launches.

Japanese technology firm Mitsubishi Electric Corporation developed a new solar-powered method for 3D printing satellite antennas in space, a press statement from the company reveals.

The new technique could reduce costs by removing the need to transport cumbersome parts that take up a lot of rocket space into orbit. As a point of reference, SpaceX typically charges about $1,200 per pound (0.45 Kg) of payload to reach low-Earth orbit.

Mitsubishi's method uses a unique "photosensitive resin" that reacts to the Sun's ultraviolet radiation, turning into a rigid solid material that's ideal for space.

Antennas are more sensitive the larger they are, meaning there is a significant limitation on the sensitivity of antennas in space due to the constraints of conventional satellite launch methods. They also have to be built to be sturdy enough to withstand the vibrations during launch without breaking, meaning they have to use heavier materials, driving up the launch cost for the satellite operator.

This means that parts that are 3D-printed in space can be much lighter and thinner than a traditional space antenna. In other words, operators will be able to launch satellites at a lower cost and with improved capabilities.

Renders showing the orbital 3D printing process. Source: Mitsubishi Electric

3D printing in space

Mitsubishi has only tested its material by simulating space-like conditions on Earth so far. The company's researchers say a 3D printed 6.5 inches (16.5 centimeters) wide antenna dish performed no differently from a traditional satellite antenna in their lab tests.

The photosensitive resin was also able to survive in temperatures of up to 750 degrees Fahrenheit (400 degrees Celsius) during tests, which means it would be suited to conditions in space. The Mitsubishi team also noted that its resin doesn't require atmospheric oxygen to prevent it from solidifying, another feature that makes it ideal for building satellite antennas. As it uses natural ultraviolet light, the company's 3D printer technology also consumes less power.

"Spacecraft antenna designs are challenging due to their conflicting requirements for high gain, wide bandwidth, and low weight," Mitsubishi announced. "High gain and wide bandwidth necessarily require a large aperture, but economical orbital deployment conventionally dictates that designs be lightweight and small enough to fit or fold inside a launch vehicle or satellite deployment mechanism."

Mitsubishi also claimed that, with its new technology, 'additive-manufacturing in space has now become possible.' However, it's worth noting that the International Space Station already features a 3D printer launched to the orbital station back in 2014. The European Space Agency also announced last year it would experiment with 3D printing in space using scrap metals from the Moon. Still, the company's new method has the potential to reduce the cost of satellite launches significantly, and it could pave the way for the construction of other vital parts for future space missions.

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: sales@prism-ipx.com
prism-ipx.com

The Wireless Messaging News
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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Tech > News Tech

OUT OF ORDER Apple warning: Millions of iPhone owners warned about bizarre iMessage bug that BLOCKS your texts

Jona Jaupi, Technology and Science Reporter
10:31 ET, May 23 2022Updated: 14:27 ET, May 23 2022

A NEW eSIM bug has been randomly deactivating iMessage and FaceTime on iPhones.

The issue was brought to light by Bloomberg's Mark Gurman last week on Twitter.

A new eSIM bug is affecting iPhones' iMessage application Credit: Getty

"There is a very nasty iPhone and TMobile bug where iMessage and FaceTime for a device’s phone number will randomly deactivate and there is no way to reactivate it," Gurman wrote.

Phone lines that utilize eSIMs — a programmable SIM card that is embedded directly into a device — are the ones being affected.

Gurman noted in his Twitter thread that the only solution that worked for him is getting a new physical SIM card.

Some users told Gurman that they had success by removing their eSIM account from their iPhone and setting it up again.

However, the iPhone expert called that method "quite complex for most people" and said it shouldn’t ever need to be done.

He then noted that he personally went directly to his phone carrier (T-Mobile), who was able to activate a physical SIM card for his phone.

Reps at T-Mobile further clarified that many customers have come in with the same issue because Apple hasn't been able to resolve it.

Gurman said that the bug has "for sure" existed on iOS 15.4, 15.5 and 15.6 beta 1.

Thousands of Users Worldwide Depend on Prism IPX

Our Customers Trust Us To Make Sure That Their Messages Get Delivered

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 email messaging, remote switch controllers, Off-The-Air paging message decoders and logging systems.

MORE INFO HERE

Providing Expert Support and Service Contracts for all Glenayre Paging Systems.

The GL3000 is the most prolific paging system in the world and Easy Solutions gladly welcomes you to join us in providing reliable support to the paging industry for many more decades in the future.

Easy Solutions provides cost effective computer and wireless solutions at affordable prices. We can help in most any situation with your communications systems. We have many years of experience and a vast network of resources to support the industry, your system and an ever changing completive landscape.

• We treat our customers like family. We don’t just fix problems . . . We recommend and implement better cost-effective solutions.
• We are not just another vendor . . . We are a part of your team. All the advantages of high priced full-time employment without the cost.
• We are not in the Technical Services business . . . We are in the Customer Satisfaction business.

Experts in Paging Infrastructure

• Glenayre, Motorola, Unipage, etc.
• Excellent Service Contracts
• Full Service—Beyond Factory Support
• Making systems More Reliable and MORE PROFITABLE for over 30 years.

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

Easy Solutions
3220 San Simeon Way
Plano, Texas 75023
Vaughan Bowden
Telephone: 972-898-1119
Telephone: 214-785-8255
Website: www.EasySolutions4You.com
E-mail: vaughan@easysolutions4you.com

May 24, 2022

Generator Used To Alert Volunteer Firefighters Of Emergencies Stolen In Douro-Dummer

Some time between 8 p.m. on Sunday and Monday, the generator that powers the Douro-Dummer paging tower was stolen, according to the Township of Douro-Dummer.

Located just south of Warsaw on County Road 38, the paging tower is used by the fire department to boost the paging signal so that volunteer firefighters can be alerted to emergencies in the community.

According to the Township, the perpetrator would have had to cut the chains to the paging tower compound to gain access to the generator.

The generator that was stolen is a HONDA EU2200i, serial number EAMT1336663. At the time it was stolen it had labels affixed to it that read "PUMP 4".

Tips that might lead to the return of the generator can be reported to:

• Crime Stoppers at 705-745-9000 (your call can be anonymous)
• OPP Reporting Centre at 888-910-1122
• Douro-Dummer Fire Services personnel Jessyka McArthur or Fire Chief Pedersen

GLENAYRE INFRASTRUCTURE

Service Contracts

I would like to recommend Easy Solutions for Support of all Glenayre Paging Equipment. This Texas company is owned and operated by Vaughan Bowden. I have known Vaughan for over 35 years. Without going into a long list of his experience and qualifications, let me just say that he was the V.P. of Engineering at PageNet which was—at that time—the largest paging company in the world. So Vaughan knows Paging.

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.

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.

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: sales@prism-ipx.com
prism-ipx.com

Home > How-to > Audio Visual

Your iPhone, iPad and Mac have a secret setting to massively boost call quality

By Becky Scarrott published 1 day ago

It's bizarrely hard to find, but it seriously levels up in-call audio

(Image: © Apple)

There's a bizarrely hidden setting in the Control Center of Apple’s iOS 15 and MacOS Monterey that you need to know about, because it significantly boosts vocal clarity when using audio and video calling apps.

The feature is called Voice Isolation and, though it was announced when iOS 15 launched (and was reported on by us here), it has tiptoed largely under the radar. But it's great, and and whenever people discover it, it tends to blow minds. It's recently blown up thanks to Twitter user can duruk and The Verge, pushing Voice Isolation and its notable perks from the depths of your Apple device's settings into the headlines.

i had no clue that a) Voice Isolation was a feature available on the new iPhones / Airpods and b) it worked so well. It's incredible on the other end — you hear nothing but the person you are talking to. Surprised it's not automatically turned on ! May 16, 2022

One of the weirdest features of Voice Isolation is that you need to be in-call to use it, but once on a WhatsApp, FaceTime (audio or video), or even Zoom call on your Apple device, toggle it on by swiping down from the top-right corner (iOS/iPadOS) or clicking (MacOS) the top right corner of your screen and selecting the 'Mic Modes' menu. It’s set to 'Standard' by default, but there are two other options: Voice Isolation and Wide Spectrum. Voice Isolation is the one you want.

Essentially, it's like noise cancelling for your voice. Your device's mics aggressively process all incoming noise and filter out extraneous background rackets to make your dulcet tones much clearer in loud environments (at a concert, about to cross a busy main road or just a crowded office desk, say).

Users have reported nothing but good things; everything from barking dogs to noisy MacBook fans has been largely nixed from calls.

To clarify, Voice Isolation works on most recent iPhones, iPads and Macs as long as you’re running iOS 15 or macOS Monterey (we tried it on an old iPhone 7 and the feature simply does not appear. On an iPhone 11, the Mic Modes menu did appear, but despite running the latest iOS 15.5, the iPhone told us that Voice Isolation was 'unavailable').

Analysis: much better audio quality, but there's a catch…

There's certainly much to celebrate here, but there are two big issues with Voice Isolation – and that's aside from the problem of having to make awkward small-talk with your caller while you deploy it in the first instance.

Firstly, Voice Isolation is not a universal setting, so you will have to manually enable it in every app you use for audio and video calls.

Secondly, because Apple makes Voice Isolation available through an API on iOS, iPadOS and macOS, there are holes in the app support. On mobile, for example, Slack, WhatsApp, Signal, and Instagram all support it, but TikTok doesn’t. For Zoom, there's iOS but not Mac support. And the biggest omission? Actual old-school phone calls — arguably the area that is in most need of it.

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
prism-ipx.com

Wireless Network Planners
Wireless Specialists

R.H. (Ron) Mercer Consultant 217 First Street East Northport, NY 11731
Telephone: 631-786-9359
wirelessplannerron@gmail.com
www.wirelessplanners.com

FCC REPORT 5/22: FCC TO CONSIDER FRANKEN-FM STATUS AND WHETHER TO EXPAND RADIO SERVICE ON CHANNEL 6

by Lance Ventaby — May 22, 2022

The FCC has introduced a proposal for rulemaking to determine whether to permanently approve the use the spectrum of television channel 6 for analog radio service on 87.75 MHz and will vote on whether to proceed with it at its June meeting.

In July 2021, all of the remaining analog low-power television stations were required to convert to digital, which would then lead to thirteen of them resuming analog audio transmission within their ATSC 3 broadcasts on an experimental basis. The rulemaking proposal seeks comments whether FM on channel 6 operations server serve the public interest and should be authorized to continue, whether they should be authorized as ancillary or supplementary services and if so subject to a new rule that permits their operation subject the certain technical and operational requirements, whether they can limit future channel 6 FM operations to those stations with active STAs, whether to consider a proposal to license additional non-commercials FMs on 82-88 MHz in areas where no television stations are operating, and whether to eliminate or revise the distance separation rules between television stations on channel 6 and radio licenses in the non-commercial band.

The full proposal can be read at this link.

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

KNOWING YOUR PLACE: THE IMPLICATIONS OF GPS SPOOFING AND JAMMING

by: Maya Posch — May 23, 2022

Artificial satellites have transformed the world in many ways, not only in terms of relaying communication and for observing the planet in ways previously inconceivable, but also to enable incredibly accurate navigation. A so-called global navigation satellite system (GNSS), or satnav for short, uses the data provided by satellites to pin-point a position on the surface to within a few centimeters. The US Global Positioning System (GPS) was the first GNSS, with satellites launched in 1978, albeit only available to civilians in a degraded accuracy mode. When full accuracy GPS was released to the public under the 1990s Clinton administration, it caused a surge in the uptake of satnav by the public, from fishing boats and merchant ships, to today’s navigation using nothing but a smartphone with its built-in GPS receiver.

Even so, there is a dark side to GNSS that expands beyond its military usage of guiding cruise missiles and kin to their target. This comes in the form of jamming and spoofing GNSS signals, which can hide illicit activities from monitoring systems and disrupt or disable an enemy’s systems during a war. Along with other forms of electronic warfare (EW), disrupting GNSS signals form a potent weapon that can render the most modern avionics and drone technology useless.

With this in mind, how significant is the threat from GNSS spoofing in particular, and what are the ways that this can be detected or counteracted?

EPHEMERAL POSITIONING

GPS autonomous positioning using the satellite navigation solution (Credit: Jan van Sickle, GPS for Land Surveyors)

The basic concept of a GNSS is fairly straight-forward: ground-based receivers listen for the signals from the satellites that are part of the specific GNSS constellation. Each GNSS satellite encodes a collection of information into this signal, which includes the position (ephemeris) of the satellite at a given time, as well as the local time on the satellite when the signal was sent.

By taking the signals from at least four of these satellites and applying the satellite navigation solution, the absolute position of the receiver can thus be determined. This uses the principle of trilateration (distance to a known point) rather than triangulation (using angles). As can be surmised, a potential issue here involves clock drift on the side of the receiver and the satellites. Perhaps less expected is that the travel speed of the signal is also heavily affected by the atmosphere, specifically the ionosphere.

This part of the atmosphere changes in thickness and composition over the course of a day, and is heavily affected by exposure to the Sun’s radiation. As a result, part of the GNSS satellite’s message contains the required atmospheric correction parameters. Because of clock-drift and the constant changes to the Earth’s atmospheric composition, each GNSS constellation has its own augmentation system. These generally consist out of a combination of ground- and satellite-based systems that provide additional information that a receiver can use to adjust the GNSS information it has received.

For use with airplane navigation, for example, it is very common to have a ground-based augmentation system (GBAS) installed using fixed receivers. These GNSS receivers then broadcast correction parameters via the airport’s VHF communication system to the airplane, helping them navigate when they approach or depart the airport.

In addition to the GNSS satellites themselves, each GNSS constellation also has its own ground-based master controller station, from which updated information on atmospheric conditions is regularly uploaded to the satellites, along with time adjustments to compensate for the satellite’s onboard clock drift. This demonstrates that a GNSS constellation is a highly dynamic system which requires constant updates in order to function properly.

Where things get interesting, however, is when attempts are made to circumvent this system, either by jamming or actively spoofing the GNSS signals.

JAM WARFARE

GNSS spoofing illustrated. (Credit: C4ADS)

The concept of jamming radio frequency communications is quite straight-forward: simply broadcast on the frequencies you wish to jam with more power than the original transmitter is capable of. Since the GNSS signal is relatively faint, this makes it easy for a ground-based system to jam this signal. Of course, since loss of a GNSS satellite fix is a known issue, backup strategies for this scenario are common, and it’s also very noticeable due to the loss of communication from a satellite.

Spoofing is a lot more subtle than jamming, as well as more versatile. Instead of merely blasting the airwaves with raw power, GNSS spoofing still involves overpowering the original signal, but instead of a denial of service (DoS) attack, spoofing is closer to a man-in-the-middle (MitM) attack, where fake satellite signals are presented to the receiver as being the genuine signals, with of course spoofed parameters that will cause the receiver to calculate a position that’s far away from where it actually is.

In a 2019 report by C4ADS (Center for Advanced Defense Studies) titled Above Us Only Stars — Exposing GPS spoofing in Russia and Syria, a number of observations are reported on where Russia has used GNSS spoofing, for a variety of reasons. An interesting and common use appears to be the spoofing of GNSS signals so that receivers think that they are located at a nearby airport. Presumably this would trigger the geofencing limitations in drones and similar, which would then refuse to take off. This could be useful during VIP visits as an anti-drone strategy, for example.

Less harmless is the military use, where during recent Russian and NATO exercises Norway and Finland reported severe GPS outages. This affected the public by limiting the navigation capacity of commercial airliners, and also disrupted the use of cellphone networks. Supposedly, in 2011 Iran used GPS spoofing to trick a Lockheed Martin RQ-170 drone to land on one of its airfields, where it was subsequently captured. Similarly, there have been multiple occasions now where marine traffic has been disrupted due to faulty GPS data being fed to the automatic identification system (AIS).

As the 2019 C4ADS report notes, this has been reported by ships in the Black Sea on multiple occasions, and also in 2019 it was reported that an American container ship — the MV Manukai — noticed very strange behavior while at the port in Shanghai, China. According to its AIS screen, one ship was shown as moving in the same channel as the Manukai, before vanishing from the screen, then appearing at the dock, before appearing in the channel and so on. When the mystified captain picked up the binoculars and scanned for this ship, it was clearly stationary at the dock that entire time.

GNSS HUNTING

GPS interference can be pinpointed based on this ring of false AIS positions. Approximately 200 meters in diameter, many of the positions in the ring had reported speeds near 31 knots (much faster than a normal vessel speed) and a course going counterclockwise around the circle. AIS data courtesy Global Fishing Watch / Orbcomm / Spire.

What’s mystifying about the GNSS spoofing as detected in Shanghai is that instead of it merely moving the calculated position to a nearby fixed point, what we see when we collate the wrong AIS data onto a map is that they form near-perfect circles. This is noted by both the MIT Technology Review article, as well as a later article by SkyTruth.

What is interesting is that when using the anonymized route information from Strava in Shanghai, this same ‘circle spoofing’ could be observed, independent from the AIS information. Somehow it would seem that the spoofed data is constantly updated, to make it appear that the affected receiver is in motion, and travelling in this large circle.

Exactly how this is done, or why, is still unknown, with no major updates since the initial reporting in 2019. Whether the intent is to hide illicit activity, or whether it’s due to some kind of cyberhacks or a glitch, nobody is entirely sure. Even independent from Iran, China and Russia, GPS-related location glitches keep happening.

Yet as a team from the University of Texas at Austin demonstrated in 2013 already using $2,000 worth of equipment and an $80 million yacht, spoofing GPS signals is relatively easy and straightforward. It doesn’t take a lot of imagination to picture what is possible today, since since that demonstration nine years ago using a university-budget, especially when upgraded to a nation-sized budget.

According to current reports, Russia is actively spoofing GPS data during the war in Ukraine, which would affect mostly private and commercial users. Whether the US military has additional backups in the case of spoofing and jamming attempts is naturally unknown, due to national security reasons. Even so, with the importance of GNSS today with navigation and so much more, it would seem pertinent to wonder whether spoofing can be detected or circumvented.

KNOWING IS HALF THE BATTLE

In an analysis by Guy Buesnel, he notes that there are quite a few risks in the GNSS chain, not the least of which is faulty equipment, and sources of interference. Perhaps the most important lesson of the past years has been that solely relying on GNSS is risky, and that adding additional ways to determine one’s position is essential, as well as the ability to detect the act of spoofing.

This aspect of detecting and possibly circumventing spoofing is currently the topic of active research, as noted by e.g. Mark L. Psiaki, et al in a recent paper. While there’s unlikely to be a silver bullet that will fix all ills and return GNSS to the infallible system that was promised to us by glossy flyers years ago, what we are likely to see the coming time are better, more robust GNSS receivers. We’re already seeing that GNSS receivers built into smartphones can use multiple GNSS constellations, with the ability to use local WiFi networks and so on as augmentation.

Using fairly low-tech improvements it would be easy to detect many spoofing attacks, such as when one’s calculated location suddenly and dramatically changes, or when one’s calculated course does not match with the data provided by the augmentation system, cell towers, or other sources of location information.

Even if GNSS isn’t the effortless panacea that many had assumed it to be, it is still a major navigational marvel, and a cornerstone of modern civilization that will continue to see improvements as it has since the first GPS satellite was launched. It just takes staying one step ahead of the meddling hackers.

EDITORIAL

In my forty-plus years in the paging industry I have known of several attempts to improve wide-area paging. During the analog TV days there were public paging systems that used the sub-carrier portion of a broadcast television transmission to transmit messages to pagers. The pagers would scan the TV broadcast band looking for the right signal in each city. It never did work very well and was a commercial failure.

And then there were the protocol competitions:

• POCSAG (3 different speeds)
• FLEX (3 different speeds)
• ReFLEX here and here
• Golay Sequential Code
• Sub-Carrier
• Mobitex
• ASCII
• ERMES
• Two-Tone Sequential
  • Tone and Voice
  • Tone Only
• 5/6 Tone
• Decimal Digital
• Metro-Page
• Five-Tone Sequential
• InFLEXion — Motorola Digital Voice

And others that I don't remember . . . confusing right? The point is that many manufacturers tried to convince everyone to standardize on one particular protocol (theirs). Over the history of the Paging Industry the two winners were POCSAG (for smaller systems) and FLEX (for large, wide-area systems).

So, I tend to doubt the validity of any new or improved Paging System at this late date.

Oh but wait a minute! You may have noticed a couple of news releases recently about a new Emergency Digital Paging over Public Television?

I had the privilege of interviewing a couple of engineers involved in this project last week and I am very impressed! Scott Yates, moderator; John Swartz, engineer, Ph.D; Paul Allan Sadowski, senior staff engineer.

I would like to do a brief comparison of existing, wide area FLEX paging systems on 900 MHz and this new Emergency Digital Paging over Public Television system. FLEX was definitely the most widely used paging protocol (internationally) when paging reached it peak in about 2000.

First: Our 900 MHz FLEX paging systems work very well. They are capable of handling many more subscribers than the number active today. These Simulcasting systems have been fine-tuned over several years, and in my not-so-humble opinion there is no current protocol that is better. Ah . . . but using this digital protocol of the Third Generation ATSC 3.0 TV looks like it will be better!

Background (from Next Gen TV):

The "NextGen" broadcast technology standard, otherwise known as ATSC 3.0, is here. Capable of 4K and HDR picture resolutions, as well as advanced Dolby audio wherewithal among other features, ATSC 3.0 is the first major overhaul to the Advanced Television Systems Committee's standard for sending and receiving over-the-air (OTA) signals since the group first introduced ATSC 1.0 back in 1996.

You may remember ATSC 1.0. That was the technology that finally took hold in 2009, ushering in the switch from analog to digital television. Capping out at 1080p high-definition resolution, ATSC 1.0 was progeny to the National Television System Committee (NTSC) standard, the antiquated analog television TV viewing experience introduced in 1941, patterned at a time when sitting in front of the TV set to watch broadcasts when they were scheduled was the norm.

ATSC 2.0 was never able to get off the launch pad—it was skipped altogether. But some of its upgrades made it into the ATSC 3.0 standard.

ATSC 3.0 will be broadly launched by individual broadcasters over the next few years, concurrent with the anticipated introduction of consumer TV products equipped to receive ATSC 3.0. The coverage goal for ATSC 3.0 is 62 markets, reaching an estimated 75% of the country. ATSC has created a map for NextGen TV deployments (opens in new tab) in the U.S.

The list of ATSC 3.0 advantages is a long one. So let's keep it to comparing paging systems.

In summary, I wholeheartedly endorse this new type of Paging. I will look forward to reports on the subscriber devices and field reception testing. Since the primary focus of this new service it to First Responders, I don't see much competition to traditional, subscriber Paging systems. More background information here.

Following are some excerpts from the eDPPT Times newsletter:

“Figure 1: eDPPT Schedule at a Glace

In mid-March, successful testing was completed at the lab of our broadcast partner PBS-NC to ensure the newly defined architecture is compliant to ATCS 3.0 and will not disturb existing broadcast content. Testing was completed by injecting simulated CAD/E911 emergency paging messages into a normalization server which sends custom data objects to Triveni Digital’s transport encoder to broadcast the data over the PBS-NC infrastructure.

These were exciting achievements, and we are excited to turn our attention to interface with CAD/E911 call centers to receive their emergency paging message output into our normalization server and engaging fire companies with live field testing in eastern NC.

Figure 3: Emergency Digital Paging over ATSC 3.0 Eco-System

Figure 3 describes the Emergency Digital Paging over ATSC 3.0 Eco-System. To bring the entire ecosystem to life, close cooperation with key partners is required and would not be possible without their expertise and dedication to the project.

Mark Simpson, President and CEO of Triveni Digital and his team provide the tools to interface to the normalization server and TV broadcasters to generate ATSC 3.0 broadcast streams. When emergency paging data is received from the server, customized software from Triveni integrates the paging data into the ATSC 3.0 broadcast stream in a dedicated sub-channel optimized for handheld, battery operated pagers, without disturbing consumer broadcast content.

A core tenet of PBS North Carolina is to serve the public with emergency communication, and they have been a staunch supporter of the project since inception. Chief Technology Officer at PBS North Carolina, Fred Engel and his team have also been instrumental during the design and test phase and brought up the dedicated sub-channel in the lab at PBS HQ in Raleigh.

Device Solutions and Our Partners in the Press!

Device Solutions Accepted as an ATSC Member In January 2022, Device Solutions applied for and was granted ATSC Voting Class membership. We are excited for the information and access this membership provides and are eager to open new channels of information flow and to foster new relationships within the industry to bring awareness to the value provided by utilizing ATSC 3.0 for emergency paging services and enabling other mobile based broadcast services.

PBS North Carolina ATSC 3.0 Based First Responder Pager System

On March 31, 2022, at the TV Tech Summit, Fred Engel, Chief Technology Officer at PBS North Carolina, discussed the ATSC 3.0 Based First Responder Pager System trials and prototype receivers. Fred provides a unique perspective on the transition from the existing emergency pager system to the ATSC 3.0 based system as an innovator and collaborator with technology companies (Device Solutions, Triveni, and WRC). Fred also provides insight into PBS-NC being well positioned as an ideal partner from project inception to the upcoming field test and commercialization. The interview can be found here.

DHS SBIR Showcase for First Responders

On March 30, 2022, Device Solutions was thrilled to be invited to virtually present our emergency Digital Paging over Public Television project at the Department of Homeland Security’s (DHS) Small Business Innovation Research (SBIR) Showcase for First Responders. From DHS:

“Our nation’s first responders are a vital component to keeping our nation safe and face challenging and life-threating situations every day. DHS works hand-in-hand with members of all first responder disciplines—law enforcement, fire services, emergency medical services and emergency management officials, as well as innovators and industry—to develop innovative solutions to the most pressing challenges faced by first responders as they respond to these hazardous situations. Through the DHS SBIR Program, small business innovators are developing new technologies to keep first responders, emergency managers, and incident commanders better protected, connected, and prepared to safeguard the homeland and respond to disasters.”

The event was attended by 275+ people who are directly involved in the first responder community and adjacent fields. In our presentation we provided a high-level summary of the problems with the current paging technology we are addressing, the ecosystem architecture of the solution, the Phase II project status, and highlighted how other applications outside emergency paging can benefit from the solutions architecture.

View From the Top Panel Discusses Strengths, Weaknesses of Towers

By J. Sharpe Smith, Inside Towers Technology Editor

With three strong carriers, a fourth carrier actively building out nationally and a lot of spectrum, speakers on the “View From the Top” panel on the second day of Connect (X) in Denver, said the outlook is extremely good for towers and for wireless infrastructure. However, uncertainty in the economy, nationally and around the world, is having an impact more than in the past.

Moderated by Jonathan Adelstein, President and CEO, the panel comprised Alex Gellman, CEO and Co-founder, Vertical Bridge; Steve Vondran, Executive Vice President and President, U.S. Tower Division, American Tower Corporation; Jeff Stoops, Director, President and CEO, SBA Communications; and Jay Brown, CEO, Crown Castle International.

“If you look at the last two downturn cycles, the tech crash and the mortgage crisis, neither one of them really touched our business day to day,” said Gellman. “But right now, we’re definitely being impacted every day by rising costs, a tight labor market, and from a debt cost standpoint.” Vertical Bridge’s debt cost has grown by 2 and a half percent since February when it did its last securitization.

Jeff Stoops, SBA Communications, said that with wireless firmly established as a staple, even with the tough times ahead, 5G growth will not be affected. “I think there is a very long road of activity,” he said. “A lot of work must be done to complete the coverage maps and then there is so much densification to allow the kinds of new use cases of 5G and the further demand on the network.”

The panel shared their disappointment in the rules that were issued from NTIA that favor fiber in its $42.5 billion Broadband Equity Access & Deployment program, which supports the build out of broadband to close the digital divide.

“The most cost effective way to deploy broadband for all would be to do it wirelessly,” said Jay Brown, Crown Castle International. “And while it doesn’t look like that’s the way it’s going, I think, I think we have tried to be supportive as an industry. As a voice from a public policy standpoint, we’ve shown over a long period of time that we can deploy the infrastructure, most efficiently, most effectively over large areas and do that wirelessly.”

Brown noted that of the $40 billion Crown has spent on infrastructure in the U.S. between towers, fiber and small cells, $10 billion has been invested in underserved communities. “I would argue that we are already delivering infrastructure that enables broadband for all and those underserved communities, and we’re going to continue to do that.”

Adelstein noted that rural users will have to wait a long time to get fiber, enduring two year backlogs just to get fiber orders filled. Stoops agreed but he still said he believes wireless will benefit from the funding of fiber.

“I don’t necessarily see it as a zero sum game with wireless because 5G and wireless mobility requires fiber,” Stoops said. “So the more fiber that gets put down, the better chances are that you’re ultimately going to get radios and antennas hung in those locations, which is really at its core what we’re all about.”

On a more positive note, the NTIA made wireless eligible for workforce development funding, specifically naming apprenticeships as a way to get it done. Adelstein sounded a note of urgency about putting that money to work to expand the wireless workforce. “We lobbied hard and said there’s a shortage of skilled workers out there,” Adelstein said. “They put us on the same level as fiber in terms of his priority for funding.”

Gellman said that the workforce shortage is one of the most important issues that WIA will be working on for the next five to 10 years. “Clearly, workforce is under pressure. Clearly, there’s a lot of activity we can see coming. And there’s bottlenecks in the workforce,” he said. “I think it’s going to really ramp up and take off, and maybe state by state as well as federal. I think there’s a real broad opportunity to do good, and do the right thing and help everybody get this infrastructure deployed.”

Steve Vondran, Executive Vice President and President, U.S. Tower Division, American Tower Corporation, said the wireless industry needs to go beyond just expanding the workforce and diversify it. “We need to recruit more young people into our workforce. We need to all evangelize that,” he said. “We need to embrace different communities to bring talent in because we’re having trouble recruiting talent into the industry, especially for jobs that aren’t sitting at a desk.”

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's partners. The firm's contact information is included at the end of this section of the newsletter.

REMINDER: Form 481 Filing System Now Open; July 1 Filing Deadline Temporarily Waived

As we reported in a previous edition of the BloostonLaw Telecom Update, the FCC has issued a limited waiver of the July 1 deadline for ETCs to file and certify Form 481 while it awaits Paperwork Reduction Act (PRA) approval for the annual data collection by the Office of Management and Budget (OMB). The FCC will announce new filing deadline in a subsequent public notice.

However, we note that the filing system is currently open, and we encourage carriers to proceed with filing as normal because it is not clear when the temporary waiver will end and how long carriers will have to file once it does. According to USAC, the Form 481 may be prepared in the system at this time, but carriers will not be able to certify the Form 481 filing until the form and instructions receive PRA approval. The certify button and bulk certify options will be disabled until PRA approval is granted.

BloostonLaw Contacts: Gerry Duffy and Sal Taillefer.

Headlines

NTIA Announces Broadband Funding Opportunity of $41.6 Billion

On May 13, 2022, the National Telecommunications Information Administration (“NTIA”) of the U.S. Department of Commerce issued a Notice of Funding Opportunity (“NOFO”) to implement federal legislation authorizing approximately $41.6 billion for U.S. broadband deployment. The structure of the NOFO describes the broad purposes of the deployment program, known at the Broadband Equity, Access and Deployment (“BEAD”) program; available amounts and key dates; eligibility information; the multi-step process for application from initial application through release of funds; certain conditions, such as “Buy American” requirements; and associated matters like NTIA contact information, reporting requirements, and oversight information. The NOFO is a voluminous, complex document. While we attempt to provide a high-level analysis below, BloostonLaw attorneys are available to answer questions and discuss specific issues. We have experience obtaining grants through NTIA’s processes and are available to assist in all aspects of application, award, and post-grant compliance.

At bottom, the NOFO outlines a process whereby states (known as “Eligible Entities”) and other political subdivisions will disburse the majority of the grant funds to broadband providers (known as “Subgrantees”), and broadband network service will have to be available to subscribers within four years from the funds’ disbursement. The grant amounts will be distributed on a competitive basis and will be determined by the Applicant’s plan to serve “unserved” and “underserved” locations, based an FCC map (yet to be released) showing digital deployment on a national basis, with state-by-state detail.

State Application Process

The initial step of the BEAD program requires a state filing of a letter of Intent (“LOI”) by July 18, 2022. The LOI will signal a state’s intent to participate in the program. If a state chooses, it may request the disbursement by NTIA of up to $5,000,000 in Initial Planning Funds (“IPF”). Such IPF request must be filed with NTIA by August 15, 2022. Importantly, the IPF amounts may be used by the states to initially identify “unserved” and “underserved” locations consistent with FCC rules and processes for identifying these locations.

After the award of IPF amounts, the recipient states will have 270 days within which to submit a Five-Year Action Plan to NTIA to address the goal of universal broadband access and adoption. The NOFO document likewise requires all Five-Year Action Plans to address and incorporate each state’s Digital Equity Plan.

On or after the FCC’s broadband data maps are made public, NTIA will notify the states (and other “Eligible Entity” interests) of available funds, and will invite the submission of an initial grant proposal and a final grant proposal. The initial proposal will be due within 180 days of an NTIA “Notice of Available Amounts”. Importantly, this initial proposal will describe the states competitive process to select subgrantees. Accordingly, our clients are urged to track state developments as to these initial proposal as it will likely impact the competitive environment among grant applicants.

Indeed, after submission of the initial proposal, NTIA expects a state run “challenge process” before the award of any BEAD program funds. This process will allow a local government, nonprofit association or broadband provider to determine whether any location or particular community is eligible for grant funds, including whether a particular location is unserved or underserved.

Once the initial proposals are approved by NTIA, 20% of the total grant funds allocated to a state will be released. The state interests will have up to one year to complete the selection process and submit a final award proposal to NTIA for the entities (or “subgrantees”) seeking the broadband funding. Upon approval of the final award proposal, NTIA will then award the remaining grant funds to the states.

State Authority in Selecting Grant Recipients

As previously noted, subgrantees will be selected by state authorities. The NOFO indicates that the selection process must be “fair, open and competitive,” but appears to leave discretion to the states as to the selection process itself. Nonetheless, NTIA has laid down 3 principles for the states in the selection process:

• Isolated Locations. An “unserved” or “underserved” project can be as small or a single location in order to be included in BEAD program.
• “Unserved” and “Underserved” projects may include middle mile infrastructure for technical or financial sustainability of a project, including service to unserved, underserved locations, or to eligible community anchor institutions (“CAIs”).
• States may not treat as unserved or undeserved any location that is already subject to an enforceable commitment to deploy qualifying broadband, or is deemed served as a result of any challenge process.

ACAM program companies constitute an example of the third condition; areas that are already subject to broadband deployment commitments under ACAM will not be treated as “unserved” or “underserved.” There are limited exceptions to this requirement. “Qualifying broadband service” is described as “Reliable Broadband Service” with speeds of not less than 100 mbps for downloads; and not less than 20 mbps for uploads with latency less than or equal to 100 milliseconds. “Qualifying broadband for CAIs is defined as speeds not less than 1 Gbps symmetrically, with the same latency requirement of 100 mbps. “Reliable Broadband Service”, in turn, means fiber optic technology, cable modem/hybrid fiber-co-axial technology, DSL, licensed spectrum technology, including hybrid licensed/unlicensed spectrum technology.

Key Take-Aways From NOFO Requirements for States and Subgrantees

Against this general background, the NOFO documents contains a number of program requirements for the states as well as deployment obligations for the subgrantee recipients. The state obligations mainly run to the initial proposal, which must be submitted to NTIA 180 days after receiving notice of available amounts from NTIA. Subgrantee obligations will follow state and NOFO requirements and will be reflected in applications/plans filed by these with the states. Below, we outline first that state requirements in the initial proposal and second, those requirements running to the subgrantee applicants.

State Reporting Requirements

• Outline long term objectives for achieving broadband deployment goals.
• Identify existing efforts to deploy broadband.
• Discuss coordination with Tribal Governments, community organizations and other stakeholders.
• Identify each unserved and underserved location under jurisdiction of the state using most recent broadband data maps from the FCC.
• Discuss identification of CAIs and deployment plans for same.
• Discuss state’s plan for challenge process.
• Discuss plan for competitive award of subgrants for last mile broadband deployment and explain how plans will minimize BEAD subsidy.
• Describe the low-cost plans that must be offered by subgrantees are consistent with the BEAD program.
• Describe the intended use of 20% funding upon approval of initial proposal.
• Describe any laws restricting broadband deployment by public sector entities and whether they will be waived for purposes of BEAD program.

Last-Mile Deployment Project Principles for States

• “Unserved” and “Underserved” projects can include isolated locations.
• “Unserved/Underserved” projects can include middle mile infrastructure for interconnection and other project – related purposes.
• Locations already subject to enforceable commitments to deploy “qualifying broadband,” such as federal, state or local commitments, may not be treated as “unserved/underserved” (though may be waived by NTIA under some circumstances).
• Subgrant process must be competitive and may include increasing subgrant match (set by NOFO at 25%) in order to reduce costs.
• State may not discriminate on basis of corporate forms (e.g., cooperatives and local governments will be eligible for grants).
• States may decline to select a proposal that exceeds the “Extremely High Cost Per Location Threshold.”
• Grant awards must require complete coverage of unserved/underserved locations, followed by prioritization of CAIs.
• States may also fund deployment of Wi-Fi technology to multi-family buildings lacking high speed broadband access.
• Greatest weight in scoring must be given to:
  • minimal use of BEAD funding (incorporating at least 25% grant waiver matching funds),
  • most affordable price to customer, and
  • demonstrated record of fair labor practices.

Obligations for Subgrantees

• Speed and latency must meet compliance standards utilized by FCC in multiple contexts (e.g., Connect America Fund and RDOF).
• Funded networks must deliver Reliable Broadband Service with speeds not less than 100 mbps/20 mbps.
• 95% of latency measurements must be at or below 100 milliseconds, round trip time.
• Funded networks for CAI’s must be capable of 1 Gbps speeds, bidirectionally.
• Network outages shall not exceed 48 hours over a 365-day period.

Deployment Deadlines and Benchmarks

• Subgrantees must deploy funded networks to customers no later than 4 years after receipt of funding.
• Interim buildout milestones must be met, as established by states.
• Fiber optic facilities and/or underground conduit must include access points for unaffiliated interconnectors, and must have sufficient capacity for such purposes, to be anticipated on a pre-construction basis.

Service Obligations

• Each subgrantee to meet state-imposed middle-class affordability plan
• Each subgrantee must offer at least one low-cost broadband service option (examples of low-cost broadband service option provided in NOFO);
• Subgrantees required to participate in Affordable Connectivity Program
• Subgrantees may not impose data usage caps; related certification requirements imposed
• Subgrantees required to carry out public awareness campaigns to highlight value/benefits of broadband service and availability of low-cost service plans

Interconnection Requirements and Wholesale Access

• Subgrantees shall permit other broadband service providers to interconnect with middle mile network facilities on reasonable, non-discriminatory basis
• NTIA encourages states to give preference to last-mile applicants who commit to offer wholesale broadband services on reasonable and non-discriminatory terms.
• Cybersecurity risk attestations required by prospective subgrantees which meet several cybersecurity government standards.
• Similar attestations covering supply chain risk management.

Qualifications

• Grant recipients required to demonstrate competence, financial and management capacity to carry out requirements of program.
  • Financial capacity showing includes certification of available funds in excess of grant securing prescribed letter of credit in a value of no less than 25% of the subaward amount;
  • opinion of counsel that letter of credit would not be impaired by any bankruptcy filing of the grantee;
  • a pro forma analysis of the proposed project demonstrating financial capability.
• Submission of organizational chart of key management detailing all parents, subsidiaries and affiliates; narrative demonstrating managerial capability and experience of similar size and scope
• Technical and operational capability showing also required:
  • Submission of network design, costs timeline and milestones for project implementation and capital investment schedule
  • Certification of operational capability to qualify to compete and operate the project. Certification of immediate, prior experience (2 years) must submit a certification to these facts, including number of years the entity or its parent has been operating
• Ownership information must be supplied in accordance with FCC rule requirements
• Disclosure of other public funding services state and federal shall also be disclosed
• Required prescribed certification for federal projects due included for subgrantees, along with references to “eligible” and “ineligible” uses of BEAD program funds, as set forth in the Code of Federal Regulation; federal environmental and Historic Preservation Act requirements also identified.

Buy American Requirements

• Requires all iron, steel and manufactured products (including fiber optic communications facilities) to be manufactured in the U.S.; waivers possible.

Other reporting and federal requirements apply to subgrantees in the NOFO; in the interest of conveying the more important information in the NOFO, we will be glad to provide a more detailed analysis for any of our clients, upon request.

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

FCC Announces Tentative Agenda for June Open Meeting

On May 18, the FCC issued the tentative agenda for its June Open Meeting, currently scheduled for June 9. At the meeting, the FCC is tentatively scheduled to consider the following items:

• Facilitating Access to Spectrum for Offshore Uses and Operations: a Notice of Inquiry seeking comment on whether changes in the Commission’s rules and policies are needed to facilitate the development of commercial and private wireless networks offshore. (WT Docket No. 22-204)
• Improving Wireless 911 Call Routing: a Public Notice to examine recent technological improvements to and deployments of location-based routing for wireless 911 calls, as well as steps the Commission could take to help reduce misrouted 911 calls. (PS Docket No. 18-64)
• Preserving Local Radio Programming: a Notice of Proposed Rulemaking regarding a proposal to allow certain channel 6 low power television stations to continue to provide FM radio service as ancillary or supplementary service under specified conditions (MB Docket No. 03-185)

The FCC will also be considering one enforcement action.

Each summary above contains a link to the draft text of each item expected to be considered at this Open Meeting. However, it is possible that changes will be made before the Meeting. One-page cover sheets prepared by the FCC are included in the public drafts to help provide an additional summary.

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

Comments on Certified Professional Engineer Requirement for Broadband Data Maps Due June 8

On May 25, the FCC published in the Federal Register its Public Notice seeking comment on the Competitive Carriers Association’s (CCA’s) petition on the requirement for a certified professional engineer to certify Broadband Data Collection (BDC) maps. Accordingly, comments are due June 8 and reply comments are due June 15.

As we reported in a previous edition of the BloostonLaw Telecom Update, CCA is requesting that the FCC issue a declaratory ruling to clarify that BDC filings may be certified by a qualified professional engineer or an otherwise-qualified engineer that is not a licensed professional engineer accredited by a state licensure board. CCA asserts that the “experience and expertise developed by [Radio Frequency (RF)] engineers through their work provides comprehensive skills relevant to broadband deployment [and] provides skills comparable to, and perhaps more relevant than, general licensure through the PE . . . exam process.” Additionally, CCA requests that the FCC clarify that the term “corporate engineering officer” may be any employee who has “direct knowledge” and is “responsible for” the carrier’s network design and construction and who possesses a Bachelor of Science degree in Engineering. Alternatively, CCA requests a limited waiver of the requirement that BDC data be certified by a licensed professional engineer, and instead allow mobile providers to certify their data with an RF engineering professional with specified qualifications that are directly relevant to broadband availability assessment. Finally, CCA recommends that if the FCC seeks to specify qualification standards or requirements for engineers to certify broadband availability, it should adopt standards that specifically relate to broadband availability assessment, such as academic and employment experience, RF and propagation modeling experience, and knowledge relevant to wireless carriers’ networks.

Carriers interested in filing comments on CCA’s proposal may contact the firm for more information.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

Law and Regulation

FCC Opens Docket on DISH AWS Buildout Compliance

On May 24, the FCC issued a Public Notice (DA 22-572) announcing the opening of a docket to monitor compliance with the conditions imposed on DISH by the Commission in connection with its July 2019 request for extension to complete construction of facilities under its AWS-4, Lower 700 MHz E-Block, and AWS H-Block licenses. The new docket (WT Docket No. 22-212) is dedicated to monitoring of nationwide 5G network deployment build out and coverage requirements as well as verification and enforcement.

As you may recall, back in September of 2020, the FCC’s Wireless Bureau issued an Order in conjunction with its T-Mobile/Sprint merger order officially modifying certain DISH Wireless Service Radio licenses and granting a waiver to extend construction deadlines conditioned on DISH's provision of 5G broadband. Closing of the T-Mobile/Sprint deal (which didn’t happen until April 1 of 2020) was a major lynchpin for DISH’s network buildout plan because of the divestiture of Boost Mobile’s assets to DISH and seven-year wholesale agreement under which DISH’s customers would have access to the post-merger T-Mobile/Sprint network.

For each of DISH’s spectrum licenses in the AWS-4 (2000-2020 MHz / 2180-2200 MHz), lower 700 MHz E block and AWS H block (1915-1920 MHz/1995-2000 MHz) bands, DISH has until June 14, 2023 to provide 5G service. That service has to cover at least 70% of the population in each license area for the AWS-4 and E block licenses, and at least 75% of the population in the AWS-H block license areas. However, there’s a caveat: If DISH builds out 5G coverage in those bands that reaches at least 50% of the entire U.S. population by that June 2023 date, then it can have another two years, until June 14, 2025, to get to the 70% or 75% mark in each of the specific license areas.

For DISH’s 600 MHz licenses, acquired in the broadcast incentive auction, the 75% build-out requirements were accelerated from June 2029 to June 2025, bringing them in line with the rest of the spectrum licenses at issue. The FCC also required DISH to build out “5G Broadband Service,” which it defined as 5G New Radio, as laid out in 3GPP Release 15 or later, that is capable of providing Enhanced Mobile Broadband (eMBB) functionality.

These obligations are significant because DISH had planned to build a narrowband IoT network to fulfill its FCC build-out requirements, but the new rules on its licenses mean that it must offer 5G NR service instead — and specifically say that each of its licenses are now “expressly conditioned on Dish building, deploying, and offering 5G Broadband Service.” Should DISH fail to meet the build-out requirements in a license area, it automatically loses that license — without further action by the FCC — and is ineligible to get it back if the commission makes the spectrum available at a later time.

DISH will also face financial penalties of up to $2.2 billion and license forfeitures if it doesn’t meet the new deadlines, starting with the potential for a $200 million penalty if it doesn’t meet its June 2022 commitments to covering 20% of the U.S. population with 5G, and to have deployed a core network. According to reports from last February, DISH is on schedule to building the first stand-alone cloud-native autonomous 5G network in conjunction with Amazon Web Services.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

Comments on Wireless Emergency Alert FNPRM due June 21

On May 23, the FCC announced that its Further Notice of Proposed Rulemaking of April 21, 2022 seeking comment on Wireless Emergency Alerts was published in the Federal Register. As a result, comments are due June 21, and reply comments are due July 19.

As we reported in a previous edition of the BloostonLaw Telecom Update, the FCC proposed that wireless providers that participate in Wireless Emergency Alerts publicly report on key aspects of the performance of this service. The FCC further sought comment on:

• How the reliability, speed, and accuracy of Wireless Emergency Alerts should be defined and whether these are the most pertinent performance measures for the service;
• How participating wireless providers should measure the performance of Wireless Emergency Alerts for the purpose of generating performance reports;
• When and how these performance reports should be provided to the FCC; and
• Whether and how these performance reports should include information collected at the consumer’s device.

Carriers interested in participating in this notice and comment proceeding may contact the firm for more information.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

proposing that commercial mobile service providers that participate in WEA report on key metrics designed to help develop an understanding of WEA’s end-to-end performance, and seeks comment on ways to improve WEA’s consistency and the pace at which messages are received.

Comment Sought on Video Content Vendor Diversity Report Petition

On May 23, the FCC issued a Public Notice seeking comment on a Petition for Rulemaking filed by FUSE, LLC et al. (Petitioners) on May 5, 2022 requesting that the Commission establish an annual report on the diversity of video programming content vendors (content vendor diversity report or CVDR). Comments are due July 22, and reply comments are due August 22.

Specifically, the Petitioners ask the Commission to require licensees and regulatees in broadcast, cable, broadband, and satellite services to collect diversity data from the content vendors they use for both their traditional, regulated platforms as well as for their affiliated or commonly owned streaming video distribution platforms. The Petitioners assert that content vendors relevant to the inquiry should include linear programming networks, such as programming services distributed on cable or satellite; over-the-top linear content sources, such as Free Advertiser-Supported TV (FAST) channels; applications made available on licensees’ or regulatees’ traditional or online platforms; production companies and studios providing content for distribution to consumers through advertiser-supported video-on-demand (AVOD) or subscription (SVOD); and other sellers of content to relevant platforms. The Petitioners suggest that, for purposes of tracking the vendors’ diversity, the Commission define “minority” using the Office of Management and Budget Statistical Policy Directive No. 15, which provides a common framework for consistent data on race and ethnicity throughout the federal government. In addition, they maintain that, at a minimum, the Commission should measure diversity along four parameters: ownership; board membership; senior leadership (i.e., executives in operational decision-making roles); and full-time employees. The Petitioners also state that the final CVDR published by the Commission should include (a) which licensees or regulatees failed to respond, including any reasons given for such refusal; (b) the total number of applicable vendors for any given licensee or regulatee; (c) the number of vendors that provided information; and (d) the findings in each diversity measurement category.

BloostonLaw Contact: Gerry Duffy.

Industry

NTIA Announces 34 States and Territories Have Signed Up for BEAD

On May 18, NTIA announced that 34 states and territories have sent in letters indicating their intent to participate in the funding opportunities known as the Biden-Harris “Internet for All” initiative, which includes the BEAD program discussed earlier in today’s edition of the BloostonLaw Telecom Update.

Since NTIA announced the initiative on Friday, the following states and territories have sent in their letter of intent or indicated they will participate: Alabama, Alaska, Arizona, Arkansas, American Samoa, California, Colorado, Connecticut, Delaware, Georgia, Hawaii, Kentucky, Louisiana, Maine, Massachusetts, Michigan, Mississippi, Montana, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Puerto Rico, Rhode Island, Tennessee, United States Virgin Islands, Utah, Vermont, West Virginia and Wisconsin.

Deadlines

MAY 31: FCC FORM 395, EMPLOYMENT REPORT. Common carriers, including wireless carriers, with 16 or more full-time employees must file their annual Common Carrier Employment Reports (FCC Form 395) by May 31. This report tracks carrier compliance with rules requiring recruitment of minority employees. Further, the FCC requires all common carriers to report any employment discrimination complaints they received during the past year. That information is also due on May 31. The FCC encourages carriers to complete the discrimination report requirement by filling out Section V of Form 395, rather than submitting a separate report.

BloostonLaw Contact: Richard Rubino.

[WAIVED; NEW DEADLINE NOT YET ESTABLISHED] JULY 1: FCC FORM 481 (CARRIER ANNUAL REPORTING DATA COLLECTION FORM). All eligible telecommunications carriers (ETCs) must report the information required by Section 54.313, which includes information on the ETC’s holding company, operating companies, ETC affiliates and any branding in response to section 54.313(a)(8); its CAF-ICC certification, if applicable; its financial information, if a privately held rate-of-return carrier; and its satellite backhaul certification, if applicable.

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

JULY 1: MOBILITY FUND PHASE I ANNUAL REPORT. Winning bidders in Auction 901 that are authorized to receive Mobility Fund Phase I support are required to submit to the FCC an annual report each year on July 1 for the five years following authorization. Each annual report must be submitted to the Office of the Secretary of the FCC, clearly referencing WT Docket No. 10-208; the Universal Service Administrator; and the relevant state commissions, relevant authority in a U.S. Territory, or Tribal governments, as appropriate. The information and certifications required to be included in the annual report are described in Section 54.1009 of the FCC’s rules.

BloostonLaw Contacts: John Prendergast and Sal Taillefer.

JULY 31: FCC FORM 507, LINE COUNT DATA (A-CAM AND ALASKA PLAN RECPIENTS). Sections 54.313(f)(5) and 54.903(a)(1) of the FCC’s rules requires all rate-of-return telecommunications carriers to provide line count information on FCC Form 507 to USAC, the universal service Administrator. Carriers receiving Connect America Fund Broadband Loop Support (CAF BLS) must submit this information annually on March 31st of each year, and may update the data on a quarterly basis. Carriers that receive Alternative Connect America Model (A-CAM) I, A-CAM II, or Alaska Plan support are required to file by July 1st of each year. For 2020, the FCC has extended the A-CAM filing deadline until July 31.

BloostonLaw Contacts: Gerry Duffy and Sal Taillefer.

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 contact: Sal Taillefer.

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) — CONTACTS — Benjamin H. Dickens, Jr., 202-828-5510, bhd@bloostonlaw.com Gerard J. Duffy, 202-828-5528, gjd@bloostonlaw.com John A. Prendergast, 202-828-5540, jap@bloostonlaw.com Richard D. Rubino, 202-828-5519, rdr@bloostonlaw.com Mary J. Sisak, 202-828-5554, mjs@bloostonlaw.com D. Cary Mitchell, 202-828-5538, cary@bloostonlaw.com Salvatore Taillefer, Jr., 202-828-5562, sta@bloostonlaw.com This newsletter is not intended to provide legal advice. Those interested in more information should contact the firm.

Calendar At-a-Glance

May
May 31 – FCC Form 395 (Annual Employment Report) is due.

June
Jun. 1 – Rural Healthcare Applications for 2022 are due.
Jun. 8 – Comments are due on BDC Engineer Certification Requirement petition.
Jun. 15 – Reply comments are due on BDC Engineer Certification Requirement petition.
Jun. 16 – 15-Day Access Tariff Filings are due.
Jun. 21 – Comments are due on Wireless Emergency Alert FNPRM.
Jun. 23 – Petitions to suspend 15-Day Access Tariff Filings are due.
Jun. 24 – 7-Day Tariff Filings are due.
Jun. 27 – Replies to Petitions to Suspend 15-Day Access Tariff Filings are due (NOON ET).
Jun. 27 – Petitions to Suspend 7-Day Tariff Filings are due (NOON ET).
Jun. 27 – Comments are due on Pole Replacement FNPRM.
Jun. 29 – Replies to Petitions to Suspend 7-Day Tariff Filings are due (NOON ET).
Jun. 30 – Inmate Calling Service data reports are due.
Jun. 30 – Reply comments are due on Pole Replacement Dispute Process.
Jun. 30 – Reply comments are due on Digital Discrimination NOI.
Jun. 30 – COVID Lifeline waivers set to expire.

July
Jul. 1 – FCC Form 690 (Mobility Fund Phase I Auction Winner Annual Report) is due.
Jul. 19 – Reply comments are due on Wireless Emergency Alert FNPRM.
Jul. 27 – Auction 109 – AM/FM Broadcast Auction begins.
Jul. 27 – Reply comments are due on Pole Replacement FNPRM.
Jul. 29 – Auction 108 – 2.5GHz Flexible-Use Auction begins.
Jul. 31 – Carrier Identification Code (CIC) Report is due.
Jul. 31 – FCC Form 507 A-CAM/Alaska Plan Line Count Data is due.

TBD
FCC Form 481 (Carrier Annual Reporting Data Collection Form) is due.

Blooston, Mordkofsky, Dickens, Duffy & Prendergast, LLP is a telecommunications law firm representing rural telecommunications companies, wireless carriers, private radio licensees, cable TV companies, equipment manufacturers and industry associations before the FCC and the courts, as well as state and local government agencies. Our clients range from Fortune 500 companies to small and medium-sized enterprises whose vitality and efficiency depend on the effective deployment of communications.

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