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Telecom Alert: Pai Asks Congress to Revoke T-Band Auction; FCC Maintains RF Exposure Limits; FCC Oversight Hearing; Effective Date for FCC Order Implementing Kari's Law and RAY BAUM's Act [Vol. XVI, Issue 49]

FCC Chairman Pai Asks Congress to Revoke T-Band Auction

On December 2, 2019, FCC Chairman Pai issued a statement asking Congress to repeal the mandate to auction T-Band Spectrum, emphasizing the FCC has extensively analyzed the band and has determined that the costs of relocating public safety licensees would far exceed potential revenue. On the same day, the Commission issued a Public Notice suspending the processing of applications for T-Band licenses in accordance with the current T-Band mandate. Legislation was introduced in the Senate in November to repeal the section of the Middle Class Tax Relief and Job Creation Act of 2012 that requires the FCC to reallocate the T-Band (Vol. XVI, Issue 44). For more information, please contact Greg Kunkle (; 202.434.4178).

FCC Maintains Current RF Exposure Limits

Last week, the Commission issued a Resolution of Notice of Inquiry, which maintained the Commission’s current RF emission exposure limits (Vol. XVI, Issue 32). The Commission stated that after review of the extensive record, they found “no appropriate basis for and thus decline to propose amendments to our existing limits at this time.” The Commission also adopted an Order which streamlines the criteria for determining when a licensee is exempt from RF exposure evaluation criteria and provides more flexibility for non-exempt licensees to establish compliance. Finally, the Commission also adopted a Notice of Proposed Rulemaking regarding RF exposure limits for future uses of wireless technologies. Comments and Reply Comments are due 30 days and 60 days, respectively, after publication in the Federal Register. For more information, please contact Al Catalano (; 202.434.4207) or Mike Fitch (; 202.434.4264).

FCC Oversight Hearing

Last week, the House Energy and Commerce Committee’s Subcommittee on Communications and Technology held a hearing on “Accountability and Oversight of the Federal Communications Commission.” All five FCC Commissioners participated. Members of the Committee commented on the need for better broadband deployment data and to promote the Broadband DATA Act (Vol. XVI, Issue 24). Regarding public safety communications, Committee Chairman Mike Doyle (D-PA) called for next-generation 911 funding and Ranking Member Greg Walden (R-OR) called for states to end 911 fee diversion. For more information, please contact Kathleen Slattery Thompson (; 202.434.4244).

Effective Date for FCC Order Implementing Kari’s Law and RAY BAUM’s Act

The FCC’s Report and Order implementing Kari’s Law and RAY BAUM’s ACT (Vol. XVI, Issue 31) was published in the Federal Register last week, setting the effective date for January 6, 2020. Kari’s Law requires businesses and institutions that operate multi-line telephone systems (MLTS) to enable users to dial 911 directly without having to dial a prefix to reach an outside line. The rules also require MLTS to notify a front desk or security office when a 911 call is made to facilitate building entry by first responders. Within one year of the effective date, “dispatchable location” information, such as the street address, floor level, and room number of a 911 caller must be conveyed with 911 calls from fixed MLTS devices. For non-fixed MLTS devices (soft phones), MLTS providers must convey automated dispatchable location information when technically feasible but may rely on the MLTS end user to provide location information manually, subject to at least one alternative. This requirement will take effect two years from the effective date. Finally, the FCC’s 911 rules are now consolidated into a single rule part. For more information, please contact Wes Wright (; 202.434.4239).

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