On June 22, 2015, the Federal Communications Commission’s (Commission) Consumer and Governmental Affairs Bureau (CGB) sought comments on the temporary small business exemption to the 2015 Open Internet Order’s Enhanced Transparency Rule.

Among other provisions, the Commission’s recent Open Internet Order includes an “enhanced transparency” rule that builds on the transparency requirements adopted in the 2010 Open Internet Order.  (The original rule was the only provision in the 2010 Order upheld by the D.C. Circuit in Verizon v. FCC.)  The Enhanced Transparency Rule requires approval by the Office of Management and Budget (OMB) before becoming effective, but the Rule will eventually require that broadband Internet access service (BIAS) providers make certain additional disclosures regarding network performance, commercial terms, and network management practices.  These disclosures are required to be in a consumer-friendly, accessible format.

Recognizing that the Enhanced Transparency Rule would heavily burden smaller BIAS providers, the Commission carved out a temporary exemption from the new rule for BIAS providers serving 100,000 or fewer customers. 
Continue Reading

On November 12, 2014, the Federal Communications Commission (FCC) announced the implementation of electronic filing procedures for common carrier complaints and pole attachment complaints under Sections 208 and 224, respectively, of the Communications Act.

Literally years in the making, the change constitutes the FCC’s latest step in expanding electronic docketing and filing as well as electronic notification regarding developments in open proceedings. The new procedures increase the accessibility of documents to members of the public by making Section 208 and Section 224-related filings available for review online through the FCC’s Electronic Comment Filing System.


Continue Reading

The Federal Communications Commission’s (“FCC’s” or “Commission’s”) new text-to-911 rules are effective today. As we discussed in a previous post immediately following the adoption of the related order, the FCC has mandated that all messaging services that permit users to send text messages using domestic telephone numbers also enable users to communicate with public emergency response providers via text messages. The FCC adopted its Second Report and Order and Third Notice of Proposed Rulemaking in the Text-to-911 proceeding on August 8, 2014. On September 16, the order and NPRM were published in the Federal Register making the rules effective today and setting the comment deadline on the NPRM for today, with reply comments due on November 17.
Continue Reading

Followers of this blog know that appeals relating to Universal Service Fund contribution obligations proliferate.  Despite a rule stating that the FCC will address such appeals in 90 days, contribution appeals routinely linger for two years or more before a decision.  Moreover, the number of new appeals outpaces the number of USF decisions issued by