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Telecom Alert: SIM Swap Petition Pleading Cycle; 24 GHz Rules Pleading Cycle; AMTS Rule Waivers; Digital Discrimination Pleading Cycle [Vol. XXI, Issue 6]

CTIA SIM Swap and Port-Out Fraud Petition Pleading Cycle

Opposition comments and replies to CTIA’s petition for partial reconsideration of the Commission’s rules aimed at safeguarding cell phone consumers from SIM swap and port-out fraud are due by February 13 and February 23, respectively [Vol. XXI, Issue 4].  The FCC’s rules mandate secure authentication methods before redirection of a customer’s phone number to a new device or provider, as well as notification to consumers about any SIM changes or port-out requests made on their accounts.  CTIA seeks an extended deadline for wireless providers to comply with the new rules by adding an additional 12 months to the current six-month compliance deadline.  For more information, please contact Wes Wright (; 202.434.4239).

24 GHz Rules Pleading Cycle

The pleading cycle has been set in the Commission’s rulemaking proceeding proposing to implement certain decisions regarding the 24.25-27.5 GHz band made at the World Radio Communication Conference in 2019 (“WRC-19”).  The Commission proposes to align part 30 of the Commission’s rules for mobile operations with the limits on unwanted emissions into the passive 23.6-24.0 GHz band adopted at WRC-19.  The rules are meant to facilitate protection of passive sensors for weather forecasting and research, while promoting flexible commercial use in the 24 GHz band.  Comments and reply comments are due by February 28 and March 14, respectively.  For more information, please contact Wes Wright (; 202.434.4239) or Tim Doughty (; 202.434.4271).

AMTS Rule Waiver Requests

PTC-220, LLC, a consortium of U.S. Class I freight railroads, filed a request for waiver with the FCC seeking multiple rule waivers and Special Temporary Authority (“STA”) to deploy positive train control (“PTC”) and non-PTC operations on 219 MHz band automated maritime telecommunications system (“AMTS”) spectrum.  The railroads also submitted a plan to justify the use of mobile transmitter power of up to 39 watts ERP.  The waiver request claims that AMTS spectrum can be leveraged to satisfy capacity demands for expanded PTC deployment and will not harm other AMTS operations.  For more information, please contact Tim Doughty (; 202.434.4271).

Digital Discrimination FNPRM Pleading Cycle

The pleading cycle has been set in response to the Commission’s Further Notice of Proposed Rulemaking (“FNPRM”) to prevent digital discrimination pursuant to Section 60506 of the Infrastructure Investment and Jobs Act (“IIJA”).  In its November 2023 FNPRM, the FCC sought comment on two sets of affirmative obligations for broadband providers to prevent digital discrimination of access, and the benefits and costs of establishing an Office of Civil Rights within the FCC.  The Commission seeks comments and reply comments by March 4 and April 1, respectively.  For more information, please contact Casey Lide (; 202.434.4186).

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