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Telecom Alert: Robocall Mitigation Database Filings; DIRS Reporting Obligations; 70/80/90 GHz Rules; CMRS Location-Based Routing Rules [Vol. XXI, Issue 5]

New 70/80/90 GHz Band Rules

The FCC adopted a Report and Order authorizing certain point-to-point links to endpoints in motion in the 71-76 GHz (“70 GHz”) and 81-86 GHz (“80 GHz”) bands.  The rules also permit the use of smaller and lower-cost antennas to facilitate backhaul service in the 70 and 80 GHz bands.  Moreover, the rules mandate a channelization plan and require certification of registered link construction to improve the accuracy of the link registration database.  For more information, please contact Wes Wright (; 202.434.4239).

CMRS Location-Based Routing Rules

The FCC adopted a Report and Order requiring Commercial Mobile Radio Service (“CMRS”) providers to deploy location-based routing technology for wireless 911 voice calls and real-time text (“RTT”) communications to 911 on their Internet Protocol (“IP”)-based networks.  CMRS providers must also use location-based routing to route calls and RTT communications originating on their IP-based networks when location information meets certain accuracy and timeliness thresholds.  CMRS providers must certify compliance with the new rules within 60 days of the applicable compliance deadlines.  For more information, please contact Wes Wright (; 202.434.4239).

Robocall Mitigation Database Filings

The FCC released a Public Notice announcing the requirement that all voice providers, including VoIP providers, must file certifications and robocall mitigation plans to the FCC Robocall Mitigation Database by February 26, 2024.  Beginning on May 28, 2024, all voice providers will be prohibited from accepting traffic from any non-gateway intermediate provider not listed in the Robocall Mitigation Database.  For more information, please contact Sean Stokes (; 202.434.4193).

Updated DIRS Reporting Obligations

The FCC adopted a Report and Order requiring cable communications, wireline, wireless, and interconnected VoIP providers to report their infrastructure status in the Disaster Information Reporting System (“DIRS”) daily when DIRS is activated in their service area.  Providers must also submit a final DIRS report to the FCC within 24 hours of DIRS being deactivated.  The rules codify the current practice of suspending reporting obligations in the Network Reporting Outage System (“NORS”) while reporting in DIRS is ongoing.  For more information, please contact Wes Wright (; 202.434.4239) or Tim Doughty (; 202.434.4271).

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