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Wireless News Aggregation

Friday — September 23, 2022 — Issue No. 1,029

Welcome Back To

The Wireless
Messaging News

Wireless Messaging News

  • Emergency Radio Communications
  • Wireless Messaging
  • Critical Messaging
  • Two-way Radio
  • Technology
  • Telemetry
  • Science
  • Paging
  • Wi-Fi
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This Week's Wireless News

  • Google wants to kill off Dolby Atmos and Vision with free versions instead
  • Critical Messaging Association Conference in Paris
    • Miscellaneous Photos
  • You Can Stop Turning Your Lights Off to Save Money
  • Regulatory Fee Payments Due September 28, 2022
    • Electronic Filing is Mandatory
    • Comcast Articulates Its Wireless Strategy
    • Reminder: Rip and Replace Program Status Updates Due October 13
    • FCC Emphasizes Need for All Towers to Evaluate Compliance Before Construction
    • SpaceX, LTD Seek Reconsideration of RDOF Application Dismissal
    • NTIA Updates BEAD Program FAQ
    • FCC Publishes New Data Specs, Software Processes for Broadband Data Collection
    • FCC Proposes $153,000 Fine for Failing to Cooperate with USAC
    • FCC Proposes 28.9% USF Contribution Factor for Q4 2022
    • FCC Authorizes 49 RDOF Winning Bids
    • USAC to Host Webinar on High Cost Audits
    • Deadlines
    • BloostonLaw Contacts
    • Calendar At-a-Glance
    • Who Is BloostonLaw
    • James Petera
    • Surround Sound
    • 80% of People Use the Wrong Screwdriver For Electrical Work
    • "Tricks Ain’t Walkin’ No More”
    • Memphis Minnie (1931)
    • Tuba Skinny Cover


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.

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

Easy Solutions  (Vaughan Bowden)
Frank Moorman
IWA Technical Services, Inc.  (Ira Wiesenfeld)
Leavitt Communications  (Phil Leavitt)
Prism-IPX Systems  (Jim Nelson & John Bishop)
Paging & Wireless Network Planners LLC  (Ron Mercer)

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.)

Qty Item Notes
2 Late IFR 500As  
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

Calibration and Repair (NIST 17025)
Upgrades: We can add the FE 5680A 10 MHz rubidium clock to your unit. Small unit fits into the well in the battery compartment — making it a world standard accuracy unit that never needs to be frequency calibrated.
Please inquire by telephone or e-mail.
Most Service Monitor Accessories in stock.

Leavitt Communications


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.

Philip C. Leavitt, V.P.
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

Google wants to kill off Dolby Atmos and Vision with free versions instead

By Matt Bolton published September 22, 2022

An alternative 3D audio and HDR option might boost Android and YouTube's options, but do we need it on TVs?

(Image credit: Google / Dolby)

Google is planning to launch its own-brand equivalent to Dolby Vision HDR and Dolby Atmos 3D audio and is trying to persuade manufacturers to support it, according to a report in Protocol (via FlatpanelsHD (opens in new tab)). Protocol says that it has seen a video of Google's presentation to hardware makers, and that the plan is known as Project Caviar.

Dolby Vision is an advanced HDR format used in the majority of the best 4K TVs, while Dolby Atmos is supported in most of the best soundbars, and is a huge selling point right now.

The big push that Google is making to manufacturers is that the two new formats would be royalty-free, meaning that manufacturers wouldn't have to pay Google any fees in order to include support for them. As FlatpanelsHD points out, Dolby Vision costs up to $3 per device to include, and the cost of Dolby Atmos is unconfirmed.

AV aficionados will note here that there is already a royalty-free alternative to Dolby Vision: HDR10+. We'll come back to that – I suspect that it's relevant for Google's final plan here.

It sounds like YouTube is the main focus for Google – the streaming site currently supports basic HDR (known as HDR10), but not the more advanced Dolby Vision version or HDR10+. And it doesn't support any 3D audio standards (the two currently in use generally are Dolby Atmos and DTS:X, but Atmos is by far the best-supported option).

But the new formats would also be a boost to Android phones. iPhones include support for Dolby Vision and Atmos, but you mostly don't get this on Android – Samsung supports HDR10+ and Dolby Atmos, but that's just about it. Google is surely hoping that it can persuade Netflix, Disney and the rest to supports its new formats, so you can get the same quality of HDR and audio on all Android devices when streaming that you get on iPhone.

Here's Dolby's illustration of why Dolby Vision is better than regular HDR – the bright lights don't blow out and become detail-less. (Image credit: Dolby

Analysis: Do we really need more HDR and audio formats?

The world of video and audio tech is already confusing enough, and full of inscrutable naming conventions. The last thing we need is more of those… but it sounds like Google's whole plan is to avoid that, which is smart for two reasons.

Let's start with the technical side. According to Protocol, Google says that the plan is to "make use of existing codecs" for its new formats (a 'codec' is name for the technology that encodes and compresses video or audio into the files that we use). If I had to guess, I'd say that Google's new HDR format will use the AV1 video codec and HDR10+ support, both of which are free for manufacturers to use.

The audio side is harder to predict, but there is already a royalty-free 3D audio tech. It's called Multi Dimensional Audio, and it's used as the basis for the DTS:X rival to Dolby Atmos. My guess is that Google will implement this technology in an existing audio file type.

The advantage of both of these approaches is that they may require minimal technical changes from TV/phone makers. The hardware needed for all of this is probably in most TVs sold today, so it might only require a software update to support the way Google will combine existing technologies into a 'new' format. Assuming this is how it works, it should massively increase the chances of it being supported on TVs in particular.

The second thing that's smart is that Google's plan here is to collect all this tech under an "umbrella brand", and I presume the names will be as simple as Dolby Vision and Dolby Atmos. You probably won't hear any of the technical terms I mention above – they'll just be called something like "HDR Sight" and "HDR Sound" or something like that.

This again gives them a chance of actually being remembered – unlike the weird names of HDR10+ or DTS:X.

Opinion: It's a nice idea, but it might be too late

In principle, I'm all for Google's plan here. There's no good reason Dolby should have all the fun here, and the price of including both Dolby Vision and Dolby Atmos support in hardware is a notable chunk of the total price of something like a streaming stick, so having a chance for hardware makers to avoid those fees but still delivery high-quality audio is great.

However, Dolby has basically been left to cement the idea that its formats are the best way to watch, and that's going to be very hard to overturn. Dolby doesn't charge streaming services to support Dolby Vision or Atmos, which is why they're in use on Netflix, Apple TV Plus, Disney Plus, Paramount Plus, Blu-rays and more. Dolby has totally embedded its name as the thing you need if you want the best quality from movies and TV.

So purely on desirability and name recognition, Google is facing an uphill battle. How will it make its own format seem like anything other than the budget alternative to the good stuff? Even if Google's new formats are exactly as good as Dolby's, they'll still struggle to make people believe that they are – and Dolby will definitely step up its own game to ensure people feel that way.

Even Amazon Prime, the main hold-out against Dolby Vision, is now starting to support it. (Image credit: Future)

And with that in mind, Google has to persuade streaming services to support it. On YouTube, it's easy – Google already auto-creates different versions of videos on that site, all based on the original best-quality one you upload. But that's probably not how it's going to be for movie streaming sites — the studios and directors won't want versions auto-converted to a different HDR or audio format. They'll want movies remastered and checked. That would be a lot of effort.

Google is presumably hoping that the promise of support on the huge number of Android devices out there will persuade services to add support, but I'm not sure about that. If people buying phones didn't care about 3D audio before, how many will care just because a software update added?

And if Google can't get the services on board, why would hardware makers get on board? I mentioned that it might technologically easy to support Google's new features, but it would still take time, effort and money — and if it doesn't look like it'd boost sales, why not just save it and stick with Dolby Vision and Atmos only on the best TVs?

I hope Google can prove me wrong and add some more competition to this space – it might take some Vision, though.

Matt Bolton
Senior Editor, TV & Audio
Matt is TechRadar's Senior Editor for TV and Audio, meaning he's in charge of persuading our team of reviewers to watch gorgeous TVs and listen to fantastic speakers and headphones. It's a tough task, as you can imagine. Matt has over a decade of experience in tech publishing, and previously ran the TV & audio coverage for our colleagues at, and before that he edited T3 magazine. During his career, he's also contributed to places as varied as Creative Bloq, PC Gamer, PetsRadar, MacLife, and Edge. TV and movie nerdism is his speciality, and he goes to the cinema three times a week. He's always happy to explain the virtues of Dolby Vision over a drink, but he might need to use props, like he's explaining the offside rule.

Source: TechRadar  

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:

IMPORTANT left arrow

“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 IPX 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.


Can You Help The Newsletter?

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You can help support The Wireless Messaging News by clicking on the PayPal Donate button above. It is not necessary to be a member of PayPal to use this service.

Reader Support

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 .


PRISM IPX Systems Critical Messaging Solutions


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.

How Can We Help You With Your Critical Messaging Solutions?


MORE INFO HERE left arrow

Easy Solutions

easy solutions

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

Critical Messaging Association Conference in Paris

The first attendance conference since 2019 has been successfully completed. It was noticeable: everyone had a great need to exchange, to talk about developments and to address the lessons learned from the past three years and to materialise their implementation.

Miscellaneous Photos:

Comments from Peter Clemons
President, Quixoticity-EU

Thanks to CRITICAL MESSAGING ASSOCIATION Chairman & e*Message Deutschland CEO, Dietmar Gollnick for inviting me to give my first in-person presentation today for almost 3 months since CCW 2022 Vienna at the excellently organised & conducted #CMAParis22. I covered a lot of ground during an hour or so this afternoon reviewing almost 30 years of our industry's history from before TCCA-Critical Communications #TETRA to 3GPP #5G & beyond, looking at the lessons learned from UK Home Office Emergency Services Network (ESN) & how we might be able to make the transition to a better future if we listen more carefully to end-users, lower over-hyped expectations for new technology & all work together cooperatively across companies, Governments, associations & standards bodies. Lots of great presentations from some old faces & a few new ones! & also so many interesting conversations during coffee, lunch & tea breaks, which just helps remind us how fantastic it is to be able to meet up in person again. And, of course, at the end of a long day, we took a group photo to remember the event & look forward to even better days during these often challenging times. Apologies if I forget to mention all of you personally. It was a large group today! And, yes, I am OK in spite of looking rather strange in the picture below, as I was standing in front of the projector!

Source: Critical Messaging Association


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.

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:

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

Telephone: 631-786-9359 left arrow

You Can Stop Turning Your Lights Off to Save Money

JASON FITZPATRICK @jasonfitzpatric SEP 21, 2022, 7:00 AM EDT | 4 MIN READ


Obsessively turning off household lights to save money is a habit most of us have, but it turns out it’s not really the money-saving power move we think it is. Here’s why you can stop.

It Saves Money, But LEDs Make It Hardly Worth It

Let us be perfectly clear right out of the gate: If you turn off a device in your home that uses electricity, no matter how big or small the device, you will, of course, save money. It doesn’t matter if the device is a giant power-hungry gaming PC or a tiny night light in the bathroom—if it isn’t using electricity, then naturally, you aren’t paying for that electricity.

When it comes to serious energy savings, however, LEDs completely changed the game. The efficiency of LED lighting compared to traditional incandescent lighting is staggering.

Back in the day, it made sense to turn the lights off when you left the room. Our parents weren’t out of line to tell us to turn the lights off and sigh when we didn’t. The total wattage of all the incandescent lights in a big room could easily exceed the wattage of a desktop computer under load, and there was an associated penalty on your electric bill and your wallet.

LED lights use a small fraction of the energy traditional incandescent bulbs do, though. Such a small fraction, in fact, that—depending on the bulbs in question—you can power anywhere from half a dozen to a dozen LED bulbs with the power required by the incandescent bulb you’re replacing.

The (Lack of) Savings by the Numbers

It helps to look at some actual concrete numbers to put it all in perspective. Let’s say, for the sake of example, that there are ten light bulbs on the ground floor of your home that you would like to keep on—for security, you just like the warm lighting in the evening, or whatever the reason might be. And let’s say you leave them on for 5 hours every night.

Suppose you have ten traditional 60w incandescent bulbs. They consume a total of 600w per hour or 0.6 kWh. You can multiply that by the cost your local utility charges for kWh, but the U.S. national average is $0.12 per kWh, so we’ll use that.

Each evening when you leave those ten bulbs on after work, it costs you $0.36. Per month, it’s $10.96, and per year it’s $131.49. That’s not early retirement money, but it’s certainly a chunk of money that could have been spent on something else like 6-12 months of your favorite streaming service, or your heat bill in the winter, or any number of things.

Now let’s say you have ten 60w-equivalent LED bulbs used under the same conditions—5 hours per day in the evening after work. Most 60w-equivalent bulbs use between 8-9w of energy, so we’ll use 8.5w for our calculations.

So now your per-hour energy use isn’t 600w, it’s 85w. At the U.S. national average energy cost, running those ten bulbs for 5 hours after work costs you $0.05 per day, $1.55 per month, and only $18.62 per year.

In fact, to get even close to the energy expense of leaving the ten incandescent bulbs on in the evening, you’d need to leave roughly seventy equivalent LED bulbs on. For many people, that would mean turning every single light on their house on, including the porch lights, garage lights, and even the attic lights, too.

Use Your Lights Guilt Free

The point of this exercise isn’t to encourage you to be wasteful for the sake of being wasteful. Efficient LEDs or not, there’s no reason to leave attic or closet lights on 24/7.

But with the efficiency of LED bulbs, flipping lights off in a room you’ll be returning to shortly or not leaving accent lights on around your house when you really love the cozy vibe they provide just doesn’t make a lot of sense. Don’t fret about wasting too much power setting up smart lights to make winter feel less gloomy or otherwise enjoying your lights.

The cost to run a 60w-equivalent LED bulb is $0.001 per hour—a tenth of a cent. At that price point, you’re talking 1,000 hours of operation to hit one dollar.

And hey, if you want to enjoy your lights extra guilt-free, unplug your lesser-used electronics or put them on a power strip you can flip off when you’re not using them

While you should leave frequently used items and crucial things like your Internet modem and router plugged in, you’ll save way more power per year by unplugging unused electronics than you will beating yourself up for leaving the kitchen lights on.

I used a Kill-a-Watt meter to check the “phantom” idle load on all my smart TVs, for example, and found that the individual TVs used around 18W of idle power. That’s two LED bulbs worth of power, 24/7, except completely wasted because it’s just powering a TV that isn’t even turned on.

So if you want to take a “there’s no such thing as a free lunch” approach to your lights, unplug your unused electronics and put that energy towards your super-efficient LED bulbs guilt-free.


Jason Fitzpatrick is the Senior Smart Home Editor at How-To Geek. He has over a decade of experience in publishing and has authored thousands of articles at How-To Geek, Review Geek, LifeSavvy, and Lifehacker. Jason served as Lifehacker's Weekend Editor before he joined How-To Geek.
Source: How-To Geek

Consulting Alliance

Brad Dye, Ron Mercer, Allan Angus, 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

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:

Regulatory Fee Payments Due September 28, 2022

Electronic Filing is Mandatory

spacerThe FCC has announced that all annual regulatory fee payments for fiscal year 2022 will be due no later than 11:59 PM ET on Wednesday, September 28, 2022. However, as discussed below, the FCC’s financial management software has been known to put licensees into “red light” status even when they have timely paid their regulatory fees, if the fee payment has not been processed by the deadline. Therefore, we recommend submitting the fee payment several days before the September 28, 2022 deadline if at all possible. Please let us know if you need assistance in preparing and/or making your regulatory fee payments. We can also help clients by preparing a filing establishing that they are exempt from having to make this payment, as discussed below.

spacerNEW THIS YEAR – All regulatory fee payors are required to use CORES for fee filing and payment via ACH and credit card. Voucher numbers will be required for wire fund transfers. Details follow in the payment instruction section below.

spacerAgain this year, the FCC’s regulatory fees have either held steady or are reduced across various categories of wireless services. It is only in a few rare instances (Domestic Satellite Earth Station) where the fees have increased from last year.

spacerLike last year, the de minimis threshold for annual regulatory fee payments will remain $1,000.00. Thus, if an entity’s total regulatory fee due is less than $1,000.00, it will be exempt from payment of the fee. This is a significant win for many of our clients.

spacerIt is important to note that a failure to make the payment by 11:59 PM ET on Wednesday, September 28, 2022 will result in the imposition of a 25 percent late payment fee and interest charges until paid in full. That said, the FCC has extended the temporary COVID-19 regulatory fee relief measures that were implemented last year in order to address the financial hardship caused by the COVID-19 pandemic. The Commission is permitted to waive or defer the payment of a regulatory fee in a specific instance if the regulatee is able to demonstrate good cause. Last year, FCC indicated that those regulatees seeking relief will be required to “unambiguously articulat[e] ‘extraordinary circumstances’ outweighing the public interest in recouping the cost of the Commission’s regulatory services.” We anticipate that the FCC will evaluate this year’s requests in a similar fashion.

Calculation of the FY 2022 Fee

The method for determining the method of regulatory fee payment is as follows:

Cellular, Broadband PCS, SMR (More than 10 MHz Bandwidth), Public Coast, Advanced Wireless Service (AWS), 700 MHz and Wireless Communications Service (WCS)

Fees are assessed annually based upon the number of telephone numbers or subscriber units. If you received an electronic Assessment Letter from the FCC regarding your CMRS cellular or mobile subscriber count, you should use the subscriber count identified on the assessment letter, which contains the FCC’s final assessment for your subscriber base unless you have challenged the subscriber count. All other CMRS cellular and mobile licensees who did not receive a letter from the FCC should use the count of telephone numbers or subscriber units as of December 31, 2021. Include in your counts any numbers that are provided to resellers and non-paying end users. The regulatory user fee is $.14 per unit in service on December 31, 2021.

With respect to the 700 MHz service, licensees have the capability of providing mobile service as well as fixed service. While it is clear that the $.14 fee per unit applies to mobile services, it is not altogether clear that it applies to fixed services, since this issue has not been addressed in the FCC’s Order. Nonetheless, the logic behind the regulatory user fee would suggest that the fee applies to both mobile and fixed subscriber units, and we suggest, out of an abundance of caution, that licensees in the 700 MHz service pay the fee on a “per unit” basis if they are providing a fixed service such as Internet access. In this way, you would avoid the costs associated with late fees, responding to FCC inquiries and clearing red-light issues. If it turns out that the regulatory fees do not apply to this service, then you could request a refund of the fee.

Air-ground Service

The unit count is based upon the number of leased transceivers provided to end-users. The regulatory user fee is $.14 per unit in service on December 31, 2021. Service provided to customer-owned units should not be included in the count.

Paging, Narrowband PCS, IMTS, Private Carrier Paging, 220 MHz, SMR (Less than 10 MHz Bandwidth), and Commercial Business Radio Service.

Fees are based upon subscriber unit counts. The regulatory user fee is $.08 per unit, in service on December 31, 2021.

Broadband Radio Service (BRS) [formerly Multipoint Distribution Service]

Fees are assessed annually. Fees are based upon the number of call signs licensed as of October 1, 2021, even though the station may not be constructed or operational until after that date. The regulatory user fee for this service is $590.00 per call sign. Please note that the regulatory fee is still due and payable even if the license was cancelled or otherwise not renewed after October 1, 2021 but before the regulatory fee payment is due.

Local Multipoint Distribution Service or (LMDS)

Fees are assessed annually. Fees are based upon the number of call signs licensed as of October 1, 2021, even though the station may not be constructed or operational until after that date. The regulatory user fee for this service is $590.00 per call sign. Please note that the regulatory fee is still due and payable even if the license was cancelled or otherwise not renewed after October 1, 2021, but before the regulatory fee payment is due. There is no fee for the Upper Microwave Flexible Use Service licenses that were carved out of the LMDS.

Domestic Satellite Earth Stations (Not Including Earth Station Receive Only)

Fees are assessed annually. Fees are based upon the number of call signs licensed as of October 1, 2021, even though the station may not be constructed or operational until after that date. The regulatory user fee for this service is $620.00 per call sign. Please note that the regulatory fee is still due and payable even if the license was cancelled or not renewed after October 1, 2021 but before the regulatory fee payment is due.

Common Carrier Fixed Point-to-Point Microwave and Private Microwave

The regulatory user fee is no longer collected on an annual basis. Instead, the fee, which for FY 2022 is $25.00 per year for the license term, will be collected at the time an application for a new station or a license renewal application is filed. Thus, since microwave licenses are granted for a ten-year term, the up-front user fee, at the time of application, would be $250.00, and would be added to the application filing-fee.

Rural Radiotelephone Service/BETRS

Regulatory user fees for these stations, which include BETRS, are no longer collected on an annual basis. Instead, the fee, which for FY 2022 is $10.00 per year for the license term, will be collected at the time an application for a new station or a license renewal application is filed. Thus, the up-front user fee, at the time of application would be $100.00, and will be added to the application filing-fee.

spacerThe FCC has indicated that it will rely on its own records, to the extent possible, in order to verify that the proper regulatory fee payments have been made. In those circumstances where its records do not contain the necessary information (e.g., mobile unit counts), it will rely on the representations made by the regulatees, subject to random audits. Therefore, in accordance with Rule Section 1.1157(d), our CMRS clients are required to keep supporting records for a minimum of two years from the date the regulatory user fees are paid. In those circumstances where an insufficient fee has been calculated, the entity will be responsible for payment of the additional fee together with any penalties and interest.

Payment Instructions

spacerMandatory Use of CORES – All regulatees that pay annually must make their regulatory fee payments electronically via credit card or ACH Payment in the Commission’s online CORES system or by wire funds transfer directly to the US Treasury. The FCC no longer accepts paper checks, cashier’s checks or money orders. In this regard, it is critical that you verify with your bank whether an ACH payment can be drawn on your account, and if so, the correct routing number and account information for this payment method, since certain banks utilize different information from what is printed on the account holders’ checks. Additionally, your bank may require the FCC’s Company ID #2700000103. Wire funds transfers to the US Treasury will be addressed below. As in prior years, the FCC no longer mails invoices for regulatory fees. These invoices are instead viewable in the FCC’s CORES System.

spacerLicensees and regulatees must first enter CORES with a valid Username and Password at:, and follow the online prompts to review their data and submit an electronic fee payment. The use of CORES to pay regulatory fees is mandatory, and payments in the form of checks, money orders, and cashier’s checks will not be accepted.

spacerPlease note that the FCC accepts VISA, MasterCard, Discover and American Express. In addition to the credit card number and expiration date, you will also need to know the security code for the credit card. Failure to provide accurate credit card information will result in rejection of the credit card payment and a 25% late fee if the payment is refiled after the payment due date. If you choose to make a payment via credit card, please note that the US Treasury has set the maximum charge that can be made on a single credit card at $24,999.99 per day. Additionally, the US Treasury does not permit the total amount due to be split into multiple payments in order to circumvent this restriction. In particular, an amount that exceeds the maximum dollar amount of $24,999.99 may not be split into two or more payment transactions in the same day by using one or more cards or over multiple days by using one or more cards. Thus, if your fee is greater than $24,999.99, it will be necessary to pay by another method such as ACH or wire funds transfer (EFT/FEDWire).

spacerShould you desire to make your payment by wire funds transfer to the US Treasury, the following instructions will apply:

ABA Routing Number: 021030004
Receiving Bank: TREAS NYC 33
Liberty Street
New York, NY 10045
BNF: FCC Acct – 27000001
OBI Field (Skip one space between each information Item): “REGULATORY PAY”
Payer FRN: (Exactly as on FCC Form 159-E Remittance Instrument)
Payer Name: (Exactly as on FCC Form 159-E Remittance Instrument)
Contact Phone or E-mail:
Voucher Number: (Exactly as on Form 159-E Remittance Instrument)

spacerWe recommend scheduling your payment for no later than Friday, September 23, 2022 in case there is an issue with the wire funds transfer. To make a wire transfer payment, please enter CORES and submit your fee information, and then complete and fax your financial institution’s wire cover memo and an electronic FCC Form 159 (or equivalent) to the Commission at (202) 418-2843, or send an e-mail to at least one hour before initiating the wire transfer (but on the same business day) so as not to delay crediting the account. Please include your FRN, Voucher Number, Payer Name, and the Amount of the Wire in the wire cover memo to assist in posting your payment quickly, and to avoid costly delays that could result in penalties and interest for missing the payment due date. Please see the following link,, for information on initiating a wire transfer. Please note that most wire transfers initiated after 6:00 p.m. (EDT) will be credited the next business day. We therefore recommend that you check with your financial institution in order to determine the appropriate deadlines for the sending of the wire transfer and receipt by the US Treasury.

spacerPlease also note that an ACH transaction could take several days for the payment to be transferred from a financial institution to the Commission. Therefore, any automated notification you receive from the Commission or following submission of your ACH payment is an acknowledgement of submission, and not an acknowledgement that the funds have been received by the Commission. As a precaution, fee payors should always check their bank statements to ensure that the funds have actually been transferred to the Commission by the regulatory fee payment due date.

Assessment Notifications

spacerThe FCC has made Interstate Telecommunications Service Providers (ITSPs) and CMRS regulatory fee assessment data available for review in its CORES system. For ITSPs, the fee assessment data is based upon the 2021 revenue data reported in the Form 499-A that was due on April 1, 2022. For CMRS providers, the fee assessment data is based upon subscriber counts derived from the Form 502 numbering report. The FCC will not be mailing out this data to CMRS providers. Because some carriers may not have filed their numbering data on the Form 502, the FCC will not have a telephone number count as of December 31, 2021. In those cases, CMRS providers should calculate their regulatory fee based upon the number of telephone numbers assigned to subscribers as of December 31, 2021.

spacerIn order to view this data and verify its accuracy, it will be necessary to log into the CORES System. Once logged into the system, you should click on the link to view the appropriate revenue data (for ITSPs) or subscriber data (for CMRS providers.) The data for ITSPs cannot be revised, since it is based upon the ITSP revenue data that was reported on the FCC Form 499-A that was filed as of April, 2022 (unless the FCC has processed a revision to the Form 499-A before its cut-off).

Payments by NECA for ITSP Fees

spacerSeveral of our wireless clients are also local exchange carriers that pay their ITSP regulatory fees through NECA. While the FCC permits regulatees to use other entities for the payment of fees, it is important to remember that the ultimate responsibility rests with the regulated entity. In this regard, it is also important to note that if there are other ITSP regulatory fees for which you are liable that are not covered through NECA (e.g., CLEC, long distance or VoIP interstate revenue), it will be necessary for you to separately initiate the payment of those fees in the FCC’s CORES system.

Exemptions from Regulatory Fees

spacerGovernmental entities and non-profit entities under Section 501 of the Internal Revenue Code are exempt from the payment of regulatory fees. Any entity claiming exempt status must submit (or have on file with the Commission) a valid IRS Determination Letter documenting its non-profit status or a certification from a governmental authority attesting to its exempt status. Additionally, a regulatee will be exempt from the payment of regulatory fees if the sum total of all of its regulatory fees owed is $1,000.00 or less. As a result, we anticipate that many of our paging clients will be exempt from paying the annual regulatory fee this year. In order to minimize the potential for being placed in a red-light status for non-payment of the regulatory fee, we recommend that any client with an exemption file a letter with the FCC that specifically states that they are exempt from the payment of regulatory fees for FY 2022. We will be glad to prepare and file such letter for you if desire.

Enforcement Actions for Non-Payment or Late Payment

spacerIn addition to the 25 percent late fee, the Communications Act has provided the Commission with three methods for enforcing user fee requirements – monetary penalties for late payment, dismissal of pending applications, and license revocations. Additionally, the FCC’s rules also permit the FCC to withhold action on any applications or requests for benefits (including USF payments) filed by anyone who is delinquent on any non-tax debt to the FCC (including regulatory fees), and to dismiss those applications or requests if satisfactory payment arrangements are not made. Finally, the Commission is authorized to pursue other remedies for non-payment of fees under the Debt Collection Act.

spacerPlease let us know if you have any questions or need any assistance with your regulatory fee payments.

spacerAny client with questions regarding this memorandum may contact Richard Rubino via e-mail at or by phone at 202-828-5519.

Source: BloostonLaw

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Inside Towers Newsletter

Friday, September 23, 2022

Volume 10, Issue 186

Comcast Articulates Its Wireless Strategy

Comcast (NASDAQ: CMCSA) has clarified its intentions for its wireless business. “We have no plans to build out a full national wireless network,” stated Tom Nagel, Comcast SVP, Wireless Strategy, in a blog post on the company’s website on Wednesday. “Rather, where it makes sense, we plan to selectively deploy our own 5G radios in dense, high-traffic areas of the markets we serve today.”

This an important position statement for the company’s competitive position and how it intends to deploy its wireless assets, as Inside Towers has reported. Comcast launched Xfinity Mobile in 2017, as a MVNO on Verizon’s network. At the end of 2Q22, Comcast reported 4.6 million wireless lines in service, still carried by Verizon. That’s tiny compared to the 355 million retail subscribers held collectively by Verizon, T-Mobile, and AT&T at the end of the quarter.

Let’s keep these numbers in context. Comcast operates in 40 states with concentrations in metro markets in the Northeast, Mid-West, the Southeast and in California. At the end of the quarter, Comcast’s cable network had passed nearly 61 million homes and businesses. Of that total, over 32 million residences and businesses, or roughly 53 percent were broadband customers. Comcast has the largest base of WiFi hotspots in the country.

Though only 13 percent of Comcast’s total customers, wireless is an increasingly strategic component of the company’s three-part wireless offerings – WiFi, MVNO on Verizon and its own 5G network – to deliver a high-quality connectivity experience for Xfinity Mobile and Comcast Business Mobile customers at home, in the office, or on the go.

Nagel points out, “Our original strategy from back in 2017 still holds true today – provide a high-quality wireless service with the best devices that delivers more value to our Internet customers and, in turn, encourages them to stay with us and attract new ones along the way.” He adds that with the three strategic pillars, Comcast’s wireless efforts turned profitable in 2021, and now is a growth opportunity.

Spectrum Holdings

Comcast has the ingredients to build its own 5G infrastructure. For starters, it has spectrum. Comcast currently holds an average of 10 MHz of 600 MHz spectrum across its operating territory. In FCC Auction 105, it spent $459 million to acquire 830 3.5 GHz CBRS Priority Access Licenses across 306 counties in its footprint. It holds at least 20 MHz of CBRS spectrum in every market and as much as 50 MHz in select markets.

“By coupling mid-band CBRS spectrum, which provides localized network capacity, with the low-band 600 MHz spectrum, which provides broad wireless coverage, we plan to efficiently deliver new 5G services that both improve our customers’ experience and lower our overall service costs,” Nagel says. “Our current spectrum holdings cover roughly 80 percent of Comcast’s homes passed and around 50 percent of the U.S. population, and those are the areas where we’ll focus. Because we know where Xfinity Mobile and Comcast Business Mobile customers use the most cellular data, we now have the option to economically deploy additional 5G capacity to better serve our customers and deliver even more value through our mobile service.”

5G RAN Equipment

Separately, on Wednesday, Comcast announced that Samsung Electronics will supply its 5G RAN equipment including a new 5G CBRS Strand Small Cell that can be mounted on existing aerial cable lines (i.e., strands), quickly and cost-effectively.

By John Celentano, Inside Towers Business Editor

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

  BloostonLaw Telecom Update Vol. 25, No. 36 September 19, 2022  

Reminder: Rip and Replace Program Status Updates Due October 13

On September 16, the FCC issued a Public Notice reminding Secure and Trusted Communications Networks Reimbursement Program (Reimbursement Program) recipients of their obligation to file status updates with the FCC every 90 days, beginning on the date on which the FCC approved the application. The next status update is due on October 13. It must inform the FCC about the work recipient has done to permanently remove, replace, and dispose of the covered communications equipment or services (i.e., all communications equipment or services produced or provided by Huawei Technologies Company or ZTE Corporation and obtained on or before June 30, 2020).

BloostonLaw Contact: Sal Taillefer.


FCC Emphasizes Need for All Towers to Evaluate Compliance Before Construction

On September 13, the FCC held a virtual workshop on environmental and historic preservation for owners and licensees using towers and other antenna structures. The all-day workshop emphasized that virtually any tower or other structure that is intended to host wireless antennas must be evaluated for compliance with the National Environmental Protection Act (NEPA) and the National Historic Preservation Act (NHPA). The latter generally requires that the owner and/or licensee reach out to the relevant State Historic Preservation Officer (SHPO), Tribal Historic Preservation Officer (THPO), and affected tribes. The FCC has established the Tower Construction Notification System (TCNS) to help facilitate this process. By filing a Form 620 report (for new towers) or Form 621 report (for modification of existing towers), antenna structure owners and licensees can efficiently seek out tribal input and determine what further consultations may be needed for an antenna structure project. The FCC has reached “Programmatic Agreements” with other NEPA/NHPA stakeholders that create total exemptions from the above requirements (primarily for antenna co-locations if certain criteria are met); and partial exemptions if other criteria are met (primarily for building antenna structures in certain industrial areas, strip malls, utility rights of way and other circumstances). These partial exemptions generally still require consultation with affected tribes.

Antenna structure owners and licensees using a structure must also determine in advance whether there will be any environmental impact from the proposed structure, by consulting with the appropriate Federal and state officials about the presence of wilderness areas, endangered species, wetlands, flood plains and other considerations. For all licensed radio operations on a structure, the licensee must determine whether there will be harmful radiation, taking into consideration not only their proposed radio operations but also the cumulative impact of all radios at the site. This must generally be determined by calculations and/or measurements, since the FCC has done away with the “categorical exclusions” that exempted most of our common carrier and private radio clients from having to verify compliance with the harmful RF radiation standards.

It is critically important that all NEPA and NHPA reviews be completed (and where required, FCC approval obtained) before construction commences. In this regard, the FCC has indicated that construction includes activities such as cutting grass, installing access roads and/or drive ways as well as laying utilities to the proposed site.

The FCC’s workshop discussed recent nuances in the compliance process, such as the impact of the NEPA/NHPA requirements on the implementation of “small cells” that are critical to advanced wireless services such as 5G. The presentations can be viewed here:

BloostonLaw can help our clients to comply with the various NEPA and NHPA requirements for new projects, and to come into compliance with any requirements that may have overlooked for existing structures (an issue that often comes up during tower sales, due diligence for company acquisitions, agreements to lease space on the tower, and protest situations).

BloostonLaw contacts: John Prendergast and Richard Rubino

SpaceX, LTD Seek Reconsideration of RDOF Application Dismissal

On September 9, Space Exploration Technologies Group (parent company of Starlink Services, LLC) (SpaceX) and LTD Broadband, LLC (LTD) filed separate Applications for Review of the FCC’s Public Notice dismissing their Rural Digital Opportunity Fund (RDOF) applications. LTD’s application was filed on an entirely confidential basis. SpaceX, which only filed certain information as confidential, argued that the FCC:

  • Misused data outside the record to penalize SpaceX alone for its system’s current speeds, which are irrelevant to whether SpaceX can meet RDOF’s speed requirements starting three years from now, as is actually required.
  • Ignored robust record evidence of SpaceX’s proven ability to quickly expand and upgrade its network.
  • Failed to accurately contrast SpaceX’s transparent all-in pricing against the opaque pricing—which disguises the true cost to consumers—common in the industry.

As we reported in a previous edition of the BloostonLaw Telecom Update, LTD Broadband was the winning bidder for $1,320,920,718.60 in RDOF funding. LTD proposed to deploy gigabit fiber to 475,616 estimated locations in 11 states. Although LTD was a relatively small fixed wireless provider before the auction, it was the largest winning bidder in the auction. Subsequently, it failed to timely receive eligible telecommunications carrier (ETC) status in seven states, rendering it ineligible in those states for support. Ultimately, the FCC review concluded that LTD was not reasonably capable of deploying a network of the scope, scale, and size required by LTD’s extensive winning bids.

Starlink, the satellite system run by Elon Musk’s SpaceX, was the winning bidder for $885,509,638.40 in RDOF funding. Starlink proposed to rely upon a nascent LEO satellite technology to provide 100/20 Mbps low latency service to 642,925 estimated locations in 35 states. In rejecting the application, the FCC observed that Ookla data reported as of July 31, 2022 indicated that Starlink’s speeds have been declining from the last quarter of 2021 to the second quarter of 2022, including upload speeds that are falling well below 20 Mbps.

In a statement, FCC Commissioner Nathan Simington said:

I welcome SpaceX’s appeal of the Wireline Competition Bureau’s decision to rescind the $885 million in Rural Digital Opportunity Fund (RDOF) funding that was awarded to its Starlink service. SpaceX won that award in a robust, competitive auction. Prior to the recent Wireline Competition Bureau decision, SpaceX appeared to me to be on track to deliver a novel high-speed, affordable service, not merely for the specific rural areas that it promised to serve as part of the RDOF program, but also for the rest of the country and potentially much of the world as well.

Commissioner Simington went on to cite concerns that failing to authorize SpaceX would also give Chinese satellite firms a competitive advantage in serving the rest of the world.

BloostonLaw Contacts: John Prendergast and Richard Rubino.

NTIA Updates BEAD Program FAQ

On September 13, the National Telecommunications and Information Administration (NTIA) posted an update to its FAQ on the Broadband, Equity, Access & Deployment Program (BEAD) program. The updated FAQ can be found here. Specifically, the new items can be found in Appendix A.

Topics covered in the update include:

  • Will BEAD cover both capital expenditures (CapEx) and operating expenditures (OpEx)? (Yes, subject to applicable cost principles.)
  • Is an area that has no fiber but is served by fixed wireless at speeds of 100/20 considered served or unserved? (Yes, it is served.)
  • Will subgrantees be allowed to deploy other offerings over a Funded Network? (Yes.)
  • Is it permissible for broadband providers to use BEAD funding to serve unserved locations within a different provider’s service area? (Yes.)
  • Who holds the title to BEAD funded assets at the end of the period of performance? (The Eligible Entity.)

BloostonLaw provided a high-level discussion of the BEAD program in the May 25, 2022 edition of the BloostonLaw Telecom Update. Since then, all states and territories have submitted applications for initial planning funds, which may be used for planning and pre-deployment activities such as research and data collection; preliminary budget for pre-planning activities; and publications, outreach, and communications support related to broadband planning, deployment, mapping, equity and adoption.

Carriers with questions on the BEAD program may contact the firm for more information.

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

FCC Publishes New Data Specs, Software Processes for Broadband Data Collection

On September 15, the FCC issued a Public Notice announcing the release of Data Specifications for Bulk Fixed Availability Challenge and Crowdsource Data, which provides guidance as to the requirements in the Commission’s rules and orders for filing bulk challenges, as well as bulk crowdsource information, to the fixed broadband availability data that will be published on the FCC’s Broadband Maps as part of the new Broadband Data Collection (BDC). The Data Specifications for Bulk Fixed Availability Challenge and Crowdsource Data, which also explains how to make the required filings in the BDC system, is available at: The bulk fixed availability challenge and crowdsource processes will open after the FCC’s Broadband Maps are published.

The FCC also established procedures for mobile wireless broadband service providers, governmental entities, and other third parties that use their own hardware and software to submit on-the-ground speed test data as part of the mobile challenge and verification processes as part of the BDC. Specifically, in describing their data collection methodology, entities submitting mobile challenges and mobile providers responding to challenges must:

  • provide a narrative overview of the overall testing solution, including a description of the test procedures and whether the testing was app-based, software-based, or hardware-based; the type of software and hardware used for the testing; and, if available, a URL link to the software and hardware products used.
  • indicate whether the testing software affects the natural behavior of a tested device, such as by locking the device to a particular radio access technology or spectrum band. In addition, parties must include information about the devices used in the testing, including supported radio access technologies, data service plan, and whether the devices have internal or external antennas (and the height of the external antennas and antenna gain, if applicable).
  • include information about the duration of speed tests and speed test servers, including server type (e.g., iperf, ookla) and main configurations between server and client (e.g., SCTP/UDP/TCP), the geographic location(s) of the server(s), the estimated number of servers, and provisioned bandwidth capacity of test servers.

Parties must submit the description of their data collection methodology into the BDC system when they submit their on-the-ground speed test data. Procedures for the preparation and formatting of mobile speed test data for submission into the BDC system are set forth in Data Specifications for Mobile Speed Test Data, located at

BloostonLaw Contacts: John Prendergast and Sal Taillefer.

Law and Regulation

FCC Proposes $153,000 Fine for Failing to Cooperate with USAC

On September 13, the FCC issued a Notice of Apparent Liability to PayG, LLC, d/b/a/ Skyswitch (PayG) for repeatedly failing to timely respond to directives from USAC to provide records that justify financial and other information reported in its 2019 and 2020 Annual Worksheets, repeatedly filing inaccurate Annual Worksheets, and willfully failing to maintain current information in CORES. A $153,000 penalty was proposed in the NAL.

According to the NAL, between May 22, 2019, and November 23, 2020, USAC repeatedly requested supporting documentation from PayG in order to verify the accuracy of PayG’s 2019 and 2020 Annual Worksheets. The Company, however, repeatedly failed to respond, or submitted non-responsive documents and late responses, over the course of this approximately 19-month period. On February 9, 2021, USAC referred this matter to the FCC’s Enforcement Bureau (Bureau) for investigation. The Bureau sent a Letter of Inquiry (LOI) to PayG on March 16, 2021. In its LOI Response, PayG acknowledged that it incorrectly reported end user revenues as reseller revenues, and also filed revisions to its 2017, 2018, 2019, 2020, and 2021 Annual Worksheets purportedly to correct the inaccuracies. USAC then requested documentation supporting the revisions. After several exchanges, USAC finally obtained all necessary documentation from PayG and concluded that revenues collected from 254 PayG customers should not have been recorded as reseller revenues on the Company’s 2019, 2020, and 2021 Annual Worksheet filings, and resulted in underpayment of USF obligations.

As with all NALs, neither the allegations nor the proposed sanctions are final FCC actions. The Companies will be given an opportunity to respond and the FCC will consider the Company’s submission of evidence and legal arguments before acting further to resolve the matter.

BloostonLaw Contacts: Ben Dickens and Sal Taillefer.

FCC Proposes 28.9% USF Contribution Factor for Q4 2022

On September 13, the FCC issued a Public Notice announcing that the proposed universal service contribution factor for the fourth quarter of 2022 will be 28.9 percent. The Commission calculates the quarterly contribution factor based on the ratio of total projected quarterly costs of the universal service support mechanisms to contributors’ total projected collected end-user interstate and international telecommunications revenues, net of projected contributions. The Universal Service Administrative Company (USAC) submitted the following projections of demand and administrative expenses for the third quarter of 2022:

($ millions)

Program Demand Projected Program Support Admin. Expenses Application of True-Ups & Adjustments Total Program Collection (Revenue Requirement)
Schools and Libraries 593.30 21.69 (5.92) 609.07
Rural Health Care 0 0 0.11 0.11
High-Cost 1,100.74 17.94 (33.62) 1,085.06
Lifeline 290.07 29.09 (107.73) 211.43
Connected Care 8.33 0.12 (0.09) 8.36
TOTAL 1,992.44 68.84 (147.25) 1,914.03

To determine the quarterly contribution base, the FCC decreases the fourth quarter 2022 estimate of projected collected interstate and international end-user telecommunications revenues by the projected revenue requirement to account for circularity and decreases the result by one percent to account for uncollectible contributions.

To arrive at the final proposed contribution base, USAC reduces each provider’s contribution obligation by a circularity discount approximating the provider’s contributions in the upcoming quarter.

BloostonLaw Contacts: Sal Taillefer


FCC Authorizes 49 RDOF Winning Bids

On September 13, the FCC authorized another 49 winning bids through the Rural Digital Opportunity Fund. For these applicants, the FCC has reviewed the long-form application information, including the letter(s) of credit and Bankruptcy Code opinion letter(s) from the long-form applicant’s legal counsel. Upon issuance of this Public Notice, the Universal Service Administrative Company (USAC) is authorized and directed to take the steps necessary to disburse from the Universal Service Fund the appropriate amounts to these applicants, to the account on file for the 498 ID associated with the study area code (SAC). The support will be disbursed in 120 monthly payments, which will begin at the end of this month.

The FCC also indicated that it will also soon post a state-level summary under the “Results” tab on the Auction 904 webpage at The summary will provide for each long-form applicant included in this Public Notice: 1) the total support amount over 10 years and total number of locations that the long-form applicant is being authorized for in each state, 2) the total number of locations to which the authorized support recipient must offer the required voice and broadband services for each performance tier and latency in each state, and 3) the eligible census blocks included in the winning bids that are being authorized in each state.

USAC to Host Webinar on High Cost Audits

On September 14, USAC announced that it will be holding a webinar on October 26 from 3 P.M. ET to 4 P.M. ET on avoiding common High Cost audit findings. Specifically, the webinar will cover methods to avoid errors such as:

  • lack of/inadequate documentation
  • improper allocation methodology
  • inaccurate data
  • inaccurate depreciation calculation
  • Improper inclusion of ineligible items, including unallowable expenses

Interested parties can register here.


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

BloostonLaw Contacts: Gerry Duffy and Sal Taillefer.

SEPTEMBER 30: FCC FORM 611-T, DESIGNATED ENTITY REPORT. Each year on September 30, entities that won licenses at auction with bid credits must file a combined 611-T Designated Entity report for any licenses still subject to the “unjust enrichment” rule, which requires licensees to maintain their eligibility for small business and rural service provider bid credits for the first five years of the license term.

BloostonLaw Contacts: John Prendergast and Cary Mitchell.

OCTOBER 15: 911 RELIABILITY CERTIFICATION. Covered 911 Service Providers, which are defined as entities that “[p]rovide[] 911, E911, or NG911 capabilities such as call routing, automatic location information (ALI), automatic number identification (ANI), or the functional equivalent of those capabilities, directly to a public safety answering point (PSAP), statewide default answering point, or appropriate local emergency authority,” or that “[o]perate[] one or more central offices that directly serve a PSAP,” are required certify that they have taken reasonable measures to provide reliable 911 service with respect to three substantive requirements: (i) 911 circuit diversity; (ii) central office backup power; and (iii) diverse network monitoring by October 15. Certifications must be made through the FCC’s portal.

BloostonLaw Contacts: Sal Taillefer.

NOVEMBER 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 and John Prendergast.

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

2120 L St. NW, Suite 825
Washington, D.C. 20037
(202) 659-0830
(202) 828-5568 (fax)


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

Sep. 22 – Replies are due in Eligible Locations Adjustment Process (ELAP).
Sep. 26 – New MTE rules come into effect.
Sep. 30 – Middle Mile Infrastructure Program grant applications are due.
Sep. 30 – FCC Form 396-C (MVPD EEO Program Annual Report).
Sep. 30 – FCC Form 611T Designated Entity Report due for Licenses subject to Unjust Enrichment rule

Oct. 13 – Deadline for status updates by Rip and Replace Program recipients.
Oct. 15 – 911 Reliability Certification

Nov. 1 – FCC Form 499-Q (Quarterly Telecommunications Reporting Worksheet) is due.
Nov. 2 – ReConnect Round 4 applications are 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.

Complete Technical Services for the Communications and Electronics Industries

Technical Services Inc.

Texas Registered Engineering Firm #F16945

“It's more than Push-To-Talk”

7711 Scotia Drive
Dallas, TX 75248-3112

Ira Wiesenfeld, P.E.

President • Principal Engineer

Cell: 214-707-7711
Toll Free: 844-IWA-TECH (844-492-8324)

Design  •  Installation  •  Maintenance  •  Training


From: James Petera
Subject: Surround Sound is amazing
To: Brad Dye
Date: September 17, 2022

I agree with you.

I have SACD and various 5.1 mixes from Pink Floyd, Yes, Rush, Billy Holiday, and several orchestra pieces. Surround sound is amazing but I must be careful to not wake the neighbors baby.

Brad's comment: Pink Floyd's “Dark Side of the Moon” was released in many different formats. I have one disc that plays in SACD on an OPPO universal disc player over a 7.2 surround sound system. It is amazing! It is similar to the original quadraphonic recording, If you want to dig into this topic some more, click here.



80% of People Use the Wrong Screwdriver For Electrical Work

There are much better options than a Phillips Head Screwdriver when doing DIY Electrical projects around the house. With minimal investment, you will have an easier time securely and safely wiring outlets and light switches using the right tool for the job.

Source: YouTube  


"Tricks Ain’t Walkin’ No More”

Memphis Minnie (1931)

Tuba Skinny Cover


Sep 5, 2022 By Lucille Bogan 1930 Del. Valley Bluegrass Festival, Salem, NJ

Tricks Ain’t Walking No More Lyrics

Times has done got hard, work done got scarce
Stealing and robbing is taking place
Because tricks ain't walking, tricks ain't walking no more
Tricks ain't walking, tricks ain't walking no more
And I'm going to grab somebody if I don't make me some dough

I'm going to do just like a blind man, stand and beg for change
Tell these tricking policemen change my second name
Because tricks ain't walking, tricks ain't walking no more
Tricks ain't walking, tricks ain't walking no more
And I've got to make no money, I don't care where I go I

'm going to learn these walking tricks what it's all about
I'm going to get them in my house and ain't going to let them out
Because tricks ain't walking, tricks ain't walking no more
Ticks ain't walking, tricks ain't walking no more
And I can't make no money, I don't care where I go

I got up this morning with the rising sun
Been walking all day and I haven't caught a one
Because tricks ain't walking, tricks ain't walking no more
Tricks ain't walking, tricks ain't walking no more
And I can't make a dime, I don't care where I go

I got up this morning, feeling tough
I got to calling my tricks and it's rough, rough, rough
Because tricks ain't walking, tricks ain't walking no more
Tricks ain't walking, tricks ain't walking no more
And I have to change my luck if I have to move next door

To purchase CD's visit

Source: YouTube  

Best regards,
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