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Telecom Alert –– FCC Order Implementing Kari's Law and RAY BAUM's Act; FCC Approves ESC Operators for 3.5 GHz CBRS Band; FCC NPRM on $20.4 Billion Universal Service Proposal; FCC Seeks Comment on MDU Broadband Rulemaking –Vol. XVI, Issue 31

Date: Aug 05, 2019

FCC Order Implementing Kari’s Law and RAY BAUM’s Act

Last week the Commission adopted a Report and Order implementing Kari’s Law and RAY BAUM’s ACT.  Kari’s Law requires multi-line telephone systems (MLTS) to enable users to dial 911 directly without having to dial a prefix to reach an outside line.  The rules also require MLTS to provide notification, such as to a front desk or security office, when a 911 call is made in order to facilitate building entry by first responders.  The Commission’s rules also require that “dispatchable location” information, such as the street address, floor level, and room number of a 911 caller is conveyed with 911 calls from fixed MLTS devices within one year.  For non-fixed MLTS devices, MLTS providers must convey automated dispatchable location information when technically feasible but may rely on the MLTS end user to provide location information manually, and alternative location information may be provided where providing  dispatchable location information is not feasible or cost-effective.  The non-fixed MLTS requirement takes effect in two years.  Finally, the Order consolidated the FCC’s 911 rules from multiple rule parts into a single rule part.  For more information, please contact Wes Wright (wright@khlaw.com; 202.434.4239).  

FCC Approves ESC Operators for 3.5 GHz CBRS Band

Last week the FCC’s Wireless Bureau and Office of Engineering and Technology announced the approval of the Environmental Sensing Capability (ESC) sensor deployment and coverage plans by CommScope, Federated Wireless, Inc. and Google.  ESCs will be used to detect and communicate the presence of any incumbent federal radar transmissions within specified geographic areas to SASs to determine priority of CBRS operations (Vol. XVI, Issue 18).  Each certified ESC must operate in conjunction with at least one Spectrum Access System (SAS) that has been approved for commercial deployment by the Commission.  Before providing commercial service, each ESC operator must file a notification with the Commission to affirm that the approved sensors covering a specific area are constructed and operational and must list the approved SASs with which the ESC is communicating.  For more information, please contact Greg Kunkle (kunkle@khlaw.com; 202.434.4178). 

FCC NPRM on $20.4 Billion Universal Service Proposal

In a Notice of Proposed Rulemaking adopted last week, the FCC proposed to establish a Rural Digital Opportunity Fund that would make up to $20.4 billion for rural broadband deployment through two multi-round, descending clock auctions, relying on procedures similar to the 2018 CAF II auction.  The Phase I auction would allocate support to census blocks not having broadband speeds at or above 25/3 Mbps with a budget of at least $16 billion over ten years.  Many of these census blocks were included in the FCC’s 2015 state-wide offers to the price cap ILECs having a performance obligation of 10/1 Mbps. The Phase II auction would make available the remaining support to unserved locations in partially unserved census blocks and in areas not won in Phase I.  In a companion Notice of Proposed Rulemaking, the FCC responded to criticisms of inadequate broadband reporting and mapping, proposing substantial revisions to the Form 477 reporting process to better identify areas and locations lacking broadband services below, at, or above the 25/3 Mbps fixed broadband benchmark.  For more information, please contact Doug Jarrett (jarrett@khlaw.com; 202.434.4180).

FCC Seeks Comment on MDU Broadband Rulemaking

The FCC is seeking comments on its recently adopted Notice of Proposed Rulemaking (NPRM) that is focused on the provision of broadband service to multitenant commercial properties and MDUs (apartment complexes) including exclusive marketing and wiring arrangements, revenue sharing agreements, and state and local regulations.  The item also addresses distributed antenna systems and rooftop leases in MDUs (Vol. XVI, Issue 25).  Comments and Reply Comments are due on August 30 and September 30, 2019, respectively.  For more information, please contact Doug Jarrett (jarrett@khlaw.com; 202.434.4180).

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Keller and Heckman LLP's Telecom Business Alert is a complimentary weekly electronic update created by the Telecommunications Practice Group of Keller and Heckman LLP.  All articles, videos, and quotations are on topics of general interest and do not constitute legal advice for particularized facts.  Keller and Heckman LLP's Telecom Business Alert © 2019.  All rights reserved.  Articles may be copied with attribution.  To sign up for our weekly alert, please send us an email at telecomalert@khlaw.com and provide us with your name and email.  Please follow us on twitter at @KHtelecom.