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Telecom Alert: Annual CPNI Certifications Due; E-Rate Funds Proposal; Comcast Delaying Internet Data Cap; NFL Seeks Partial Waiver for CBRS System [Vol. XVIII, Issue 6]

Annual CPNI Certifications Due March 1

The FCC issued a Public Notice last week reminding telecommunications carriers and interconnected VoIP providers of their obligation to file their annual certification documenting compliance with the Customer Proprietary Network Information rules (CPNI) by March 1, 2021.  CPNI includes sensitive personal information about customers, and the Commission’s rules seek to ensure that CPNI is adequately protected from unauthorized access.  Failure to comply with the requirements may lead to enforcement action, including monetary forfeitures of up to $207,314 for each violation or each day of a continuing violation, up to a maximum of $2,073,133.  For more information, please contact Jim Baller (; 202.434.4175) or Sean Stokes (; 202.434.4193).

FCC Proposes Using E-Rate Funds for Remote Learning

Last week, the FCC released a Public Notice seeking comment on several petitions for emergency relief requesting permission to use E-Rate program funds to support remote learning during the COVID-19 pandemic.  Many eligible schools and libraries explain that they are hampered in their ability to address the connectivity needs brought on by the pandemic because of the restrictions on off-campus use of E-Rate-funded services and facilities.  The Commission seeks comment on the specific equipment and services that E-Rate should support to fund off-campus access to broadband as well as how to prioritize the funding, among other issues.  Comments are due by February 16, 2021, and reply comments are due by February 23, 2021.  For more information, please contact Tim Doughty (; 202.434.4271).

Comcast Delaying Internet Data Cap

The Pennsylvania Office of Attorney General announced last week that Comcast has agreed to delay its planned implementation of data usage caps and overage charges until July 2021 in its Northeast Division (Vol. XVII, Issue 48).  Comcast planned on imposing a data cap of 1.2TB in select northeastern states, including Pennsylvania, and charging customers for exceeding that threshold.  In addition to delaying the overage charges, Comcast agreed to forgo the usage cap on certain low-income users for the duration of 2021, disclose data threshold information more prominently in the contract execution process, and waiving early termination fees normally charged for cancelling all Xfinity services through December 31, 2021 for select customers.  For more information, please contact Jim Baller (; 202.434.4175), Sean Stokes (; 202.434.4193), or Casey Lide (; 202.434.4186).

NFL Seeks Partial Waiver for CBRS System

The National Football League (NFL) filed a Request for Partial Waiver last week seeking a waiver of FCC rules to allow the operation of a general access CBRS system being tested to enable coach-to-coach communications during NFL football games.  The request is for a very limited set of circumstances in which Internet service is interrupted or becomes unavailable during or immediately prior to the game, but after authority to operate the SBRS system for that game has been granted by the SAS.  The NFL stated that the CBRS system would shut off within 60 seconds of the outage to allow the continuation of the use of the CBRS system for the remainder of the game.  To minimize the risk of an Internet outage, the NFL will use at least two independent ISPs.  For more information, please contact Greg Kunkle (; 202.434.4178) or Wes Wright (; 202.434.4239).