Among the items being considered at the upcoming April 12, 2019 Federal Communications Commission (“FCC” or “Commission”) open meeting is possible regulatory forbearance of certain legacy regulatory and structural requirements applicable to Bell Operating Companies (“BOCs”), price cap local exchange carriers (“LECs”), and independent rate-of-return carriers (“RoR carriers”). Acting on a nearly year-old USTelecom petition, the FCC’s draft Memorandum Opinion and Order (“Order”) proposes to forbear from enforcement of three regulatory requirements: (i) that independent RoR carriers offer in-region long distance service through a separate affiliate (“structural separations”); (ii) that BOCs and price cap LECs do not discriminate in service provisioning intervals and that they file special access provisioning reports; and (iii) that BOCs provide nondiscriminatory access to poles, ducts, conduits, and rights-of-way (collectively, “pole attachments”). However, the draft Order declines to decide on USTelecom’s request for forbearance from certain network unbundling and resale requirements. The Commission’s deferral on the unbundled network elements (“UNE”)/resale issue is not surprising in light of the significant industry and consumer opposition to this aspect of USTelecom’s petition. With the exception of the few comments supporting USTelecom’s petition, the vast majority of comments were relatively silent regarding the other forbearance requests. If adopted, the draft Order will be effective upon release.

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As we noted in a prior post,  on June 24, 2016, the Federal Communications Commission (Commission) adopted new mandatory network outage reporting requirements for submarine cable licensees.  The Commission’s Submarine Cable Network Outage Reporting Order (Order), released Tuesday, identifies Commission expectations and provides exact rule language for the reporting requirements which had been described at only a high-level during the Commission’s June Open Meeting.  The reporting requirements apply to all submarine cable licensees and will become effective six months after Office of Management and Budget (OMB) approval.  While the OMB approval process could extend for several months or more, affected submarine cable licensees should familiarize themselves with the reporting rules and begin developing internal mechanisms and procedures to ensure compliance once the rules become effective.

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World Global ConnectionsThe Federal Communications Commission (Commission) today adopted  mandatory network outage reporting requirements for submarine cable licensees less than a year after proposing to do so.  This mandatory reporting reflects a significant change from the voluntary submarine cable outage reporting system currently in place.  The new rules will apply to all submarine cable licensees, regardless

The Federal Communications Commission (FCC or Commission) has long-required regulated telecommunications service providers (as well as VoIP providers) and equipment manufacturers to make their services and devices accessible to individuals with disabilities.  These entities also must annually certify to the FCC their compliance with the disabilities access requirements.  These compliance measures have become fairly routine for most regulated entities.  As of 2016, however, broadband Internet access service (BIAS) providers are now among those that must comply with disabilities access requirements, and the FCC has taken affirmative steps to remind these entities of their obligations under the Communications Act and Commission rules.


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iStock_000036215158LargeYesterday, the Federal Communications Commission (“FCC”) released a Public Notice reminding telecommunications service providers, VoIP providers and advanced communications service (“ACS”) providers and equipment manufacturers of their obligation to maintain records of their efforts to implement accessibility requirements, and to annual certify their recordkeeping efforts. The April 1, 2015 filing will certify to compliance during 2014.
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stock_02032014_0596In January 2013, the Federal Communications Commission (“FCC”) comprehensively revised its reporting rules applicable to providers of international telecommunications, making numerous substantive revisions to the categories of providers subject to the reporting requirements, the information to be reported and the format of the reports. See our advisory on the January 2013 Order.
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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

While the rest of the Enforcement Bureau has not yet fully emerged from the FCC transition, the Spectrum Enforcement Division continues to move investigations along. Last month, the division fined several wireless carriers for failing to file hearing aid compatibility reports. Yesterday, the division settled two outage reporting investigations involving wireless carriers. In both cases,