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Telecom Alert - 3.5 GHz Auction; FCC Investigates Sprint Lifeline Subsidies; NG911 Institute Briefing; Electronic Filing NPRM - Vol. XVI, Issue 39

3.5 GHz Auction Procedures Open for Comment

At the September Open Meeting, the FCC issued a Public Notice seeking comment on procedures for the auction of Priority Access Licenses (PALs) in the 3.5 GHz band (Vol. XVI, Issue 36).  The Notice seeks comment on several proposed aspects of the auction including upfront payment and minimum opening bid amounts, bidding round format, and the option for bidders to bid at a Cellular Market Area (CMA) level in the 172 CMAs classified as Metropolitan Statistical Areas.  Comments and reply comments are due on October 28 and November 12, 2019, respectively.  For more information, please contact Greg Kunkle (; 202.434.4178).

FCC Investigates Sprint Lifeline Subsidies

The FCC announced last week that Sprint is under investigation for violating the “non-usage” rule of the Lifeline program by allegedly receiving subsidies for roughly 885,000 Lifeline subscribers even though those subscribers were not using the service.  Under the non-usage rule, providers are only reimbursed for a Lifeline subscriber if that subscriber has used the service at least once in the past thirty days.  Providers must also de-enroll inactive subscribers after giving them 15 days’ notice.  Sprint’s 885,000 subscribers represent almost 30% of Sprint’s Lifeline subscriber base and nearly 10% of the entire Lifeline program.  For more information, please contact Doug Jarrett (; 202.434.4180).

NG911 Institute Hosts Congressional Staff Briefing

On September 27th, the NG911 Institute hosted a Lunch and Learn Briefing at the Russell Senate Office Building on the current state of 911 and the need to modernize the Nation’s 911 system.  The event offered input from different perspectives of the public safety and emergency response community, such as originating service providers, niche 911 service providers, and public safety access point (PSAP) professionals.  Speakers included Eric Hagerson (T-Mobile), Matthew Gerst (CTIA), Brian McNealy (Comtech), Walt Kaplan (RapidDeploy), Chris Freeman (Marshall County, KY) and Dave Mulholland (Arlington, VA).  For more information, please contact Wes Wright (; 202.434.4239) or Kathleen Slattery (; 202.434.4244). 

Electronic Filing NPRM Published in Federal Register

Today, the FCC’s NPRM seeking comment on requiring all Universal Licensing System (ULS) filings to be made electronically (Vol. XVI, Issue 37) was published in the Federal Register.  The NPRM also proposes mandatory electronic filing in the Antenna Structure Registration (ASR) System as well as for certain filings and communications made in the Tower Construction Notification System (TCNS) and E-106 System. Comments and Reply Comments on the NPRM are due October 30, 2019 and November 14, 2019, respectively.  For more information, please contact Wes Wright (; 202.434.4239).

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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 and provide us with your name and email.  Please follow us on twitter at @KHtelecom.