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Telecom Alert - FCC to Consider Rules Implementing Kari's Law and RAY BAUM's Act; Commission Open Meeting; New iPhones Operate on FirstNet Spectrum; Regulatory Fee Extension for Hurricane Florence - Vol. XV, Issue 39

FCC to Consider Rules Implementing Kari’s Law and RAY BAUM’S Act

The first item on the agenda for the FCC’s Open Commission Meeting on September 26 is a Notice of Proposed Rulemaking (NPRM) that would impact emergency calling in a number of ways, as required by both Kari’s Law and RAY BAUM’S Act.  Kari’s Law was enacted by Congress earlier this year and requires multi-line telephone systems (MLTS) to enable users to dial 911 directly without having to dial a prefix to reach an outside line (See, Vol. XV, Issue 7).  RAY BAUM’S Act requires the FCC to conduct a rulemaking proceeding to consider rules that would ensure a “dispatchable location” is conveyed to public safety answering points (PSAP) regardless of the technological platform used.  The NPRM proposes rules to implement Kari’s Law, initiates a rulemaking proceeding on dispatchable location as required under RAY BAUM’S Act, and would consolidate the FCC’s 911 rules into a single part.  For more information, please contact Wes Wright (202.434.4239;

September Commission Open Meeting

At the Open Meeting later this week, the Commission is expected to adopt an already controversial  Declaratory Ruling and Report and Order that will set out a series of FCC interpretive rulings under Sections 253 and 332(c)(7) of the Communications Act looking to facilitate the deployment of 5G wireless infrastructure.  The agenda also includes a Report and Order that would establish new rules for the assignment of toll free numbers, including an auction to secure the rights to use the 17,000 mutually-exclusive applications for “833” toll free numbers. Finally, the Commission will hear a presentation on the results of the recent Connect America Phase II auction (Auction 903) (Vol. XV, Issue 36).  For more information, please contact Doug Jarrett (; 202.434.4180).

New Apple iPhones Support Operation on FirstNet Spectrum

AT&T announced that the new Apple iPhone XS and iPhone XS Max have built-in support for Band 14, which is the spectrum set aside for public safety and makes up the all-band solution upon which FirstNet is built.  The devices are now available for pre-order on the FirstNet web portal.  Urgent Communications reported that previous Apple devices had been certified for use by FirstNet subscribers, but none of the previous Apple products have achieved the “FirstNet Ready” designation, which is reserved for devices that can operate on Band 14 spectrum. The iPhone XS and iPhone XS Max today became the first Apple products designated as FirstNet Ready devices.  For more information, please contact Al Catalano (; 202.434.4207).

Regulatory Fees Extended for Those Affected by Hurricane Florence

Earlier this month the Commission announced that the filing fee deadline for FY 2018 Regulatory Fees is September 25, 2018.  Licensees of certain facilities, such as Satellite Earth Stations, are required to make annual regulatory fee payments.  For many licensed facilities, such as microwave and land mobile systems, the regulatory fees are paid when the application is filed with the FCC.  Last week, the Commission’s Office of Managing Director announced that the regulatory filing fee window for regulatees affected by Hurricane Florence has been extended to September 27, 2018.  For additional information, please contact Tim Doughty (; 202.434.4271).

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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 © 2018.  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.