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Telecom Alert: Net Neutrality Effective Date; Equipment Authorization NPRM; Broadband Data Collection Updates; Aeronautical Study Delays [Vol. XXI, Issue 22]

Net Neutrality Effective Date Announced

The effective date has been set for the FCC’s Declaratory Ruling, Report and Order, Order, and Order on Reconsideration reclassifying broadband Internet access service (“BIAS”) as a telecommunications service under Title II of the Communications Act of 1934. The rules will take effect July 22, 2024, except for certain transparency rule amendments that require BIAS providers disclose network management practices, performance, and commercial terms to consumers. The transparency rule amendments have been delayed indefinitely and the effective date for their implementation will be published in the Federal Register at a later date. For more information, please contact Casey Lide (; 202.434.4186), Sean Stokes (; 202.434.4193), or Jim Baller (; 202.434.4175).

Equipment Authorization Program NPRM

The FCC released a Notice of Proposed Rulemaking (“NPRM”) that proposes to prohibit any Telecommunications Certification Bodies (“TCBs”) or test labs in which any entity on the Commission’s Covered List has direct or indirect ownership from participating in the equipment authorization program. The prohibition would be triggered by direct or indirect ownership of 10% or more, and TCBs and test labs would be required to report any entity that holds a 5% or greater direct or indirect equity and/or voting interest in them. The FCC also seeks comment on whether the Commission should impose eligibility restrictions for TCBs and test labs based on lists developed by the Executive Branch agencies. For more information, please contact Greg Kunkle (; 202.434.4178), Wes Wright (; 202.434.4239), or Tim Doughty (; 202.434.4271).

Broadband Data Collection Proposed Updates

The FCC is considering updates to the Broadband Data Collection (“BDC”) that would clarify and strengthen the audit procedures used to validate availability data and modify the data collection requirements and validation processes to improve the precision of the National Broadband Map. The circulated Order and Declaratory Ruling would also create a process to better account for changes in network deployments over time. The FCC releases updated versions of its National Broadband Map every six months based on the data collected through the BDC. For more information, please contact Sean Stokes (; 202.434.4193).

FAA Aeronautical Study Delays

The FAA is advising that off-airport aeronautical studies can be expected to have an additional 15-day processing time, on top of the average four to six weeks it already takes to process them. The FAA expects to have the issue causing the processing delays resolved sometime in August. The FAA reminds applicants that aeronautical studies are processed on a first come, first served basis, but if a planned construction requires priority review, the FAA will consider requests for escalation if a satisfactory rationale is provided upon submission of the aeronautical study request. For more information, please contact Wes Wright (; 202.434.4239) or Tim Doughty (; 202.434.4271).

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