Telecom Alert: 911 Reliability Certification System; CBRS NPRM; BDC NPRM Pleading Cycle; $160,000 Penalty for Unauthorized Satellite [Vol. XX, Issue 34]
911 Reliability Certification System Open
The FCC announced that its 911 Reliability Certification System is now open for filing annual reliability certifications, which are due on October 15, 2024. The Commission’s rules require covered 911 service providers to take reasonable measures to provide reliable 911 service. The annual reliability certifications are used to detail a provider’s 911 circuit diversity, central office backup power, and diverse network monitoring capabilities. Filings can be submitted online at: https://apps2.fcc.gov/rcs911/. For more information, please contact Wes Wright (wright@khlaw.com; 202.434.4239) or Tim Doughty (doughty@khlaw.com; 202.434.4271).
Citizens Broadband Radio Service NPRM
The FCC released a Notice of Proposed Rulemaking (“NPRM”) proposing adjustments to the regulatory framework of the Citizens Broadband Radio Service (“CBRS”) to better protect federal users and facilitate spectrum access for commercial broadband. The proposal would modify the Part 96 rules to reflect mechanisms currently used to protect federal users in the 3.5 GHz band. The Commission also seeks comment on whether the 3.5 GHz protection methodologies should be aligned with adjacent bands, whether it should revisit its Environmental Sensing Capability (“ESC”) approval procedures, and how best to continue to introduce CBRS outside of the contiguous United States. The FCC is also considering ways to improve the service rules for the 3.5 GHz band to reflect changes experienced by Priority Access License (“PAL”) holders and General Authorized Access (“GAA”) users. For more information, please contact Greg Kunkle (kunkle@khlaw.com; 202.434.4178), Wes Wright (wright@khlaw.com; 202.434.4239) or Tim Doughty (doughty@khlaw.com; 202.434.4271).
Broadband Data Collection NPRM Pleading Cycle
The pleading cycle for the FCC’s Fourth Notice of Proposed Rulemaking to update the Broadband Data Collection (“BDC”) processes has been set. The Commission seeks comment on proposed changes to the BDC availability data filing process that would limit publication of data on “grandfathered” services, collect terrestrial fixed wireless spectrum authorization information, and additional certifications and supporting data from satellite broadband providers. Additionally, the Commission seeks comment on amendments and clarifications to several of its BDC data validation rules. Comments and reply comments are due on September 16 and October 15, 2024, respectively. For more information, please contact Sean Stokes (stokes@khlaw.com; 202.434.4193).
$160,000 Penalty for Unauthorized Satellite Operations
The FCC entered into a Consent Decree with Intelsat License LLC (“Intelsat”) to resolve an investigation into alleged violations of the Commission’s rules related to the unauthorized operation of a space station. Intelsat received authorization to deploy its Galaxy 35 satellite at 95.05 degrees West Latitude and notified the FCC that the satellite had arrived at its authorized location in 2013, when in fact the satellite had arrived at 94.85 degrees West Latitude. As part of the Consent Decree, Intelsat admits that it violated the FCC’s rules by deploying its Galaxy 35 satellite to an unauthorized orbital location. Intelsat will implement a three-year compliance plan and pay a $160,000 civil penalty. For more information, please contact Tim Doughty (doughty@khlaw.com; 202.434.4271).
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