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Telecom Business Alert - 9-1-1 MLTS Bill, CISA, PSAP Architecture; Drones; FirstNet, Pole Attachment Rates - Vol. XIII, Issue 8

9-1-1 MLTS Legislation 

Legislation has been introduced in Congress by a bipartisan group of Senators seeking to require Multiline Telephone Systems (MLTS) to be able to directly dial 9-1-1.  Many users of MLTS systems, primarily at places of employment, currently do not have effective 9-1-1 service because the systems do not provide the location information with the 9-1-1 call to enable emergency responders to know the actual location of the emergency.  Senate Bill 2553, if passed, will amend the Communications Act to prohibit any person from manufacturing, importing, selling, leasing, or installing a MLTS system unless it allows a user to directly initiate a call to 9-1-1.  However, the bill does not seek to require MLTS systems to be capable of providing the actual location of an emergency.  For more information, please contact Wes Wright (wright@khlaw.com; 202.434.4239).

CISA Implementation

Last week, the Department of Homeland Security (DHS) released several guidance documents under its Automated Indicator Sharing (AIS) initiative to assist private sector and federal entities to share cyber threat indicators with the Federal Government.  The releases are part of DHS’ mandated requirements under the Cybersecurity Information Sharing Act of 2015 (CISA) (Vol. XII, Issue 44).  DHS also released interim privacy and civil liberties guidelines which govern the receipt, retention, use, and dissemination of cyber threat indicators by a federal entity.  For more information, please contact Tracy Marshall (marshall@khlaw.com; 202.434.4234).      

PSAP Architecture

The FCC’s Task Force on Optimal PSAP Architecture (TFOPA) released a final report summarizing its work efforts on Cybersecurity, the Optimal Approach to NG9-1-1 Architecture Implementation, and the Optimal and NG9-1-1 Resource Allocation.  Among many other findings, the TFOPA stated in its report that focusing on PSAP consolidation is neither constructive nor within the exclusive scope of its work, and therefore the TFOPA has focused on funding mechanisms for state and local governments.  For more information, please contact Wes Wright (wright@khlaw.com; 202.434.4239).  Mr. Wright will give a presentation on the TFOPA’s report at the APCO Western Regional Conference in Portland, Oregon on March 10, 2016.

Drone Lawsuit

A Washington, D.C.-based think tank has filed a petition with the DC Circuit Court of Appeals challenging the FAA’s Unmanned Aircraft System (UAS) registration requirements for small recreational drones.   Last month, the FAA issued a press release disclosing that almost 300,000 owners of small unmanned aircraft (drones) registered their aircraft with the agency online in response to the FAA’s registration requirements effective December 21, 2015 (Vol. XIII, Issue 5).  The petition challenging registration argues  the FAA exceeded its authority to regulate aircraft registration, because it requires registration of people who own model aircraft, not the aircraft themselves.  The petition also argues the FAA failed to provide the public with notice of the new regulation and an opportunity to comment before it was implemented.  For more information, please contact Greg Kunkle (kunkle@khlaw.com; 202.434.4178).   

FirstNet RFP

Since releasing its Request for Proposal to build a nationwide public safety broadband network (NPSBN) (Vol. XIII, Issue 3) in January, FirstNet has received over 400 questions and requests for clarification. FirstNet has now released the first batch of responses, with more to come soon.  FirstNet also issued an amendment to the RFP extending the Submission of Capability Statements due date to 2:00 p.m. Eastern time on March 31, 2016, and the Submission of Proposals due date to 2:00 p.m. Eastern time on May 13, 2016.  For more information, please contact Al Catalano (catalano@khlaw.com; 202.434.4207).

Correction - Lower Pole Attachment Rates Now Effective March 4, 2016

The FCC’s Order lowering the “Telecom” pole attachment rate that investor-owned utilities can charge in the 30 “FCC states” is now effective March 4, 2015, as a result of a correction published in the Federal Register. For more information, please contact Tom Magee (magee@khlaw.com; 202-434-4128).

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Keller and Heckman LLP's Telecom Business Alert is a complimentary weekly electronic update created by the Telecommunications and the Business Counseling and Transactional practice groups 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 © 2016.  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.