Communications and Technology Alert: Tentative December Open Meeting Agenda; Strategic Subsea Cables Act Introduced; Equipment Authorization Order Effective Date; CPUC E-Rate Petition for Reconsideration [Vol. XXII, Issue 48]
Commission Releases Tentative December Open Meeting Agenda
On November 25th, the Commission announced it would be tentatively considering three items during the December Open Meeting, scheduled for Thursday, December 18, 2025. The agenda includes a Third Report and Order and Third Further Notice of Proposed Rulemaking (FNPRM) which would require VoIP services to implement modern measures to protect consumers from illegal robocalls, including filing updated robocall-related certifications and ownership and control disclosure information in line with the Commission’s foreign ownership rules. The FNPRM would seek additional comment on reclaiming numbering resources and restrictions on VoIP numbering authorizations. The Commission will also consider a Report and Order clarifying LPTV service regulation, and a Direct Final Rule repealing outdated provisions in Part 2, 15, and 18 of the Commission’s rules. For more information, please contact Wes Wright (wright@khlaw.com; 202.434.4239) or Tim Doughty (doughty@khlaw.com; 202.434.4271).
Senate Introduces Undersea Cable Security Bill
On November 24th, Senators Jeanne Shaheen (D-NH) and John Barrasso (R-WY) introduced the Strategic Subsea Cables Act of 2025 to address gaps in security and international engagement in protecting undersea cable networks. The bill directs the Secretary of State to increase U.S. engagement with the International Cable Protection Committee (ICPC) and produce recommendations for Congress to further such engagement. The bill also details sanctions proceedings in the event of damage to subsea cable networks, further reporting on foreign cable manufacturing, and the development of inter-agency plans to increase threat information sharing with subsea cable operators and owners. For more information, please contact Wes Wright (wright@khlaw.com; 202.434.4239) or Tim Doughty (doughty@khlaw.com; 202.434.4271).
Commission Announces Effective Date for Equipment Authorization Order
In October, the Commission adopted a Second Report and Order which clarified the prohibition on authorization of certain equipment and services on the Commission’s Covered List and developed procedures for limiting previously granted authorizations of covered equipment in order to prevent further importation but allow for continued operation of such equipment. Notably, the Order clarified that “modular transmitters” would be considered covered equipment and placed on the List. The Order also clarified the term “produced by” as it relates to attestations required to determine whether a piece of equipment is identified on the List. On November 25th, a notice in the Federal Register stated that the Report and Order would go into effect on December 26, 2025. For more information, please contact Wes Wright (wright@khlaw.com; 202.434.4239) or Tim Doughty (doughty@khlaw.com; 202.434.4271).
CPUC Files Petition for Reconsideration of Reversal of Wi-Fi Hotspot E-Rate Decision
The California Public Utilities Commission (CPUC) has filed a Petition for Reconsideration in response to the Commission’s Declaratory Ruling reversing E-Rate support for the use of off-premises Wi-Fi hotspots, particularly on school buses, as well as connectivity programs for schools and libraries. The CPUC states that the Commission’s reversal would directly impact low-income, rural, and underserved communities, and contradicts the Commission’s principal of universal service. The petition also claims that the Commission did not follow a proper rulemaking process to consider public comment. Lastly, CPUC states that contrary to the Commission’s argument, the Communications Act’s plain language permits the Commission to authorize support for connectivity to “locations other than the school [and] locations other than the library.” For more information, please contact Casey Lide (lide@khlaw.com; 202.434.4186) or Sean Stokes (stokes@khlaw.com; 202.434.4193).
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