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Telecom Business Alert – 800 MHz Channels, ILEC Joint Use Disputes, FirstNet, Annual CPNI Certifications Due, 76-81 GHz Radar Systems, Complimentary Emergency Communications Plan Webinar, Net Neutrality , Vol XII Issue 7

Date: Feb 18, 2015

800 MHz Channels, ILEC Joint Use Disputes, FirstNet, Annual CPNI Certifications Due, 76-81 GHz Radar Systems, Complimentary Emergency Communications Plan Webinar, Net Neutrality

Interstitial 800 MHz Channels

Last week, the FCC released a Notice of Proposed Rulemaking (NPRM) that would create full power, 12.5 kHz channels offset between currently allocated 25 kHz channels in the 809-817/854-862 MHz band. The 25 kHz channels in this band would remain, and licensees would not be required to reduce bandwidth to 12.5 kHz. The Commission proposes making these interstitial channels available for licensing once 800 MHz rebanding has been completed in a region. The proposed rules also assign eligibility to each new interstitial channel based on the eligibility assignment of the lower-adjacent existing 25 kHz channel. Frequency coordination will still be required for licensees seeking a new 12.5 KHz interstitial channel. Comments will be due 45 days after the NPRM is published in the Federal Register, and Reply Comments are due 15 days thereafter. Please contact Greg Kunkle (kunkle@khlaw.com; 202.434.4178) with questions.

FCC Guidance on ILEC Joint Use Disputes

The FCC Enforcement Bureau last week released its first Order in a series of pending ILEC pole attachment complaint proceedings against electric utilities. The Order addresses a number of important areas and in some respects should be helpful to utilities negotiating rates and other terms and conditions of attachment with their ILEC joint use partners. If you have any questions about this ruling, please contact Tom Magee (magee@khlaw.com; 202.434.4128).

FirstNet State Consultation Process

FirstNet completed an initial Consultation Meeting with the State of Texas last week as it continues its outreach efforts.FirstNet already has completed initial consultation meetings with 13 states, and  consultations with 16 additional states are scheduled between now and early September. In an article published last week in Radio Resource Mission Critical Communications magazine, Keller and Heckman Attorney Al Catalano explained that the statutorily-mandated state consultation process is the perfect vehicle for FirstNet and the states to design and implement early builder/pilot projects with specific learning objectives to demonstrate immediate, real-world success. A handful of early builder projects already have been approved by FirstNet, and additional projects will result in long-range learning with immediate real-world benefits to public safety. For more information, please contact Al Catalano (catalano@khlaw.com; 202.434.4207).

Annual CPNI Certifications Due March 1, 2015 

Earlier this month, the Commission issued an Enforcement Advisory reminding telecommunications carriers and interconnected VoIP providers to file their Customer Proprietary Network Information (or "CPNI") compliance report with the FCC by March 1, 2015. In the past, the Commission has taken enforcement action against companies failing to file their CPNI certifications with the Commission. The FCC has indicated it intends to continue strict enforcement of the CPNI requirements. For additional information, please contact Tracy Marshall (marshall@khlaw.com; 202.434.4234).

FCC Proposes Rules for 76-81 GHz Radar Systems

Earlier this month, the FCC released a Notice of Proposed Rulemaking to authorize licensed radar operations in the 76-81 GHz band. This band has multiple existing users, including unlicensed, level probing radar systems used by many critical infrastructure companies. Portions of the band also are used for automotive collision avoidance radar applications and radar systems that detect foreign object debris at airports. The NPRM proposes rules that would permit fixed radar infrastructure applications for detection of stopped vehicles or pedestrians on roads, obstacle detection capability for industrial machinery, and security monitoring. Comments are due 30 days after the NPRM is published in the Federal Register, and Reply Comments are due 45 days after Federal Register publication. Please contact Wes Wright (wright@khlaw.com; 202.434.4239) with questions.

Complimentary Emergency Communications Plan Webinar

At 1:30 p.m. EDT on Thursday, March 12, Keller and Heckman will host a complimentary webinar discussing the National Emergency Communications Plan and the critical role of the nation’s utilities in national security.  Al Catalano, Keller and Heckman Counsel, will be joined by Rear Admiral Ronald Hewitt, USCG (Ret.), Director, Office of Emergency Communications, DHS.  The webinar is complimentary, but registration is required.  Click here to register.  For additional information, please contact Mr. Catalano (catalano@khlaw.com; 202.434.4207).

Net Neutrality Update

Last week Keller and Heckman Partner Doug Jarrett was interviewed by LXBN TV regarding his recent article on the FCC’s draft Net Neutrality rules proposing Title II regulation.  Mr. Jarrett’s article on Net Neutrality can be found at Beyond Telecom Law Blog.

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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 © 2015.  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.