On September 26, 2013, the Federal Communications Commission released a Notice of Proposed Rulemaking (“NPRM”) in which it will address and update rules and policies applying to wireless infrastructure builds. The NPRM proposes a series of rule changes designed to remove barriers to the expansion of wireless infrastructure, especially for Distributed Antenna

A May 2013 California Public Utilities Commission decision requires most companies holding a California CPCN or wireless registration (“WIR”) to submit a $25,000 continuous performance bond. The decision also revises application/registration requirements, increases filing fees and sets a minimum annual User Fee.   In addition, the CPUC will convene a workshop to consider whether to require VoIP providers to register with the Commission.

The primary impact of this decision for most providers in California will be the new performance bond requirement.  The CPUC’s bond requirement takes effect on August 21, 2013.  Thereafter, entities failing to obtain a performance bond may be subject to revocation proceedings.

Continue Reading California Requires Most Carriers to Post a Performance Bond

At its open meeting this month, the Federal Communications Commission (FCC) received a status report on the implementation of broad disabilities access obligations passed three years ago.  In the presentation, FCC staff members reported that the Commission met all of the implementation deadlines in the Twenty-First Century Communications and Video Accessibility Act (CVAA), and reminded service providers and equipment manufacturers of the upcoming deadlines for compliance with the Act.

The FCC’s new disabilities access rules apply potentially significant new obligations to a variety of entities that may not otherwise consider themselves subject to the FCC’s jurisdiction.  These rules are being implemented in stages, with many obligations taking full effect in the next six months.  Providers of advanced communications services and equipment manufacturers should review these obligations carefully to ensure that their services and equipment are compliant with the new requirements.

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Continue Reading FCC Highlights Progress in Implementing CVAA Requirements

We posted recently on rules the Federal Communications Commissions (FCC or Commission) adopted in January modifying the scope of and particulars of the annual International Traffic and Revenue reports and Circuit Status reports many international providers must file annually.   The effective date of those rules, which will extend certain reporting requirements to one- and

Earlier this month, the FCC simplified the information that must be provided in certain international reports, action that should be welcomed by many carriers that have been subject to these reporting requirements.  The FCC’s Second Report and Order (“Second Streamlining Order”) in IB Docket No. 04-112 built on its May 2011 First Report and Order and Further Notice of Proposed Rulemaking eliminating or revising certain international reporting obligation.  As a result of this latest action, most international telecommunications carriers will be required, once the new rules take effect, to file annual International Traffic and Revenue reports and Circuit Status reports (collectively, the “Annual International Reports”) under a streamlined Section 43.62 of the FCC’s Rules.  The Second Streamlining Order directs the International Bureau to establish and maintain a consolidated filing manual reflecting the rulings in the Second Streamlining Order.

The Second Streamlining Order does impose requirements on some new classes of providers.  It extends the requirement to file the Traffic and Revenue Report to providers of both international interconnected Voice over Internet Protocol (“VoIP”) service and international “one-way” VoIP services.  One-way VoIP services are those VoIP providers that permit users either to receive calls from or place calls to the public switched telephone network, but not both.  The Second Streamlining Order also requires for the first time a Circuit Status report from all submarine cable licensees, not just licensees that are common carriers, as well as for international common carrier terrestrial and satellite circuits of facilities-based common carriers and the non-common carrier circuits of satellite operators.

The Annual International Reports will retain their current separate filing deadlines — March 31 for the Circuit Status Report and July 31 of the Traffic and Revenue Report. The effective date of the rule changes is currently unknown; it is at present unclear if the requirements will go into effect in time for the filing of either of the International Reports this year.  The Office of Management and Budget must first approve the reporting and filing changes.  The FCC expressly directed parties in the Second Streamlining Order to continue filing the Annual International Reports pursuant to its existing rules until it announces the new reporting requirements have become effective.

Continue Reading Annual Reporting Requirements for International Carriers Revised; VoIP Providers and Certain Non-Common Carriers Now Obligated to File

Compliance with a carrier’s CPNI certification obligations has provided steady fodder for this blog, with the annual Omnibus CPNI fines, unusual settlements and consistent enforcement focus from the FCC’s enforcement bureau.  With the start of a new year, the CPNI season begins anew.  Yeasterday, the FCC unofficially kicked off the 2012 CPNI certification season with

On October 24, the FCC Laboratory published a number of new and updated documents through its Knowledge Database (“KDB”) that liberalize further the equipment authorization process for a number of product types, including Software Defined Radios (“SDRs”).  That same day, the Lab released numerous other KDB publications providing guidance regarding both its RF exposure test procedures applicable to cellphones, smartphones, laptops, tablets, and other categories of devices, and the Commission’s “Permit But Ask” (“PBA”) procedures, which enable telecommunications certification bodies (“TCBs”) to test equipment for compliance with RF emissions limits even though the Commission has issued only partial guidance or where a certain amount of FCC oversight is still considered necessary.  Together, these changes are designed to allow a broader range of consumer devices subject to equipment authorization requirements prior to their being offered for sale, imported, or otherwise marketed to reach the marketplace quickly by allowing importers, manufacturers, and service providers to get them certificated more rapidly than in the past through the TCB process.

This wave of KDB publications, which are effective immediately subject to certain conditions in some cases, comes only one week after the FCC announced that a draft Notice of Proposed Rulemaking (“NPRM”) is on circulation among the Commissioners that would consider (a) codification of and refinements to the FCC’s permit-but-ask (“PBA”) procedure, (b) further articulating the post-grant obligations of TCBs, (c) requiring labs that manufacturers and importers use to test radiofrequency equipment to be accredited, and (d) officially recognizing the latest industry testing standards.  The text of the NPRM is not yet available and it is uncertain when the Commission will adopt the NPRM, which it is expected to do.

Continue Reading FCC Lab Offers Major New Guidance on Equipment Authorization and RF Exposure Evaluation Procedures and Announces Notice of Proposed Rulemaking on Circulation at the Commission

In several earlier posts, we informed you the FCC had adopted mandatory outage reporting regulations for both facilities-based and non-facilities-based interconnected Voice over Internet Protocol (VoIP) service providers.  The FCC has now established those rules will take effect before the end of the year.  For more details on the VoIP outage reporting regulations, see

As is customary every year, the FCC recently announced the due date for its annual FCC regulatory fees. Regulatory fees must be paid no later than 11:59 PM on September 13, 2012, Eastern Daylight Time. Most federal licensees and other regulated entities must pay these regulatory fees to offset costs associated with the FCC’s

The FCC recently announced revisions to its debt collection process for those carriers that are delinquent in contributing to the FCC’s Universal Service Fund (“USF”), Telecommunications Relay Services Fund (“TRS”) and North American Numbering Plan Fund (“NANP”) (collectively the “Funds”). Under the new procedures, the Fund administrators will forward delinquent accounts directly to the United States Department of Treasury (“Treasury”) for collection (where a 28% collection fee is added), rather than forwarding them to the FCC first. In addition, the FCC will no longer send delinquency notices to contributors for these types of debts.

These revisions could have a significant impact on telecommunications providers, who now may receive only a single notice before an outstanding debt is transferred to Treasury for collection. Contributors will have to exercise greater diligence to ensure that they receive notices of delinquent obligations to the Funds and do not mistakenly incur collection fees.

Continue Reading Revised FCC Debt Collection Processes for Delinquent Support Fund Obligations Shift Burdens to Carriers