BloostonLaw Telecom Update Published by the Law Offices of Blooston, Mordkofsky, Dickens, Duffy & Prendergast, LLP [Selected portions reproduced here with the firm's permission.] www.bloostonlaw.com | | Vol. 12, No. 22 | JUNE 3, 2009 |
McDowell, Baker Reportedly Will Fill Republican FCC Seats Senate Republicans appear to have agreed on reap pointing FCC Commissioner Robert McDowell and appointing former Commerce Department official Meredith Attwell Baker to fill the GOP seats on the Commission, paving the way for confirmation hearings in June, according to the Wall Street Journal. This could pave the way for a confirmation hearing in June for Julius Genachowski (President Obama’s choice for FCC Chairman) and one Republican FCC nominee. Another hearing for the remaining two FCC nominees would likely be scheduled later. On the Democratic side, the White House has al ready nominated Genachowski and Mignon Clyburn, a South Carolina public utilities commissioner and daughter of House Majority Whip James Clyburn of South Carolina. The holdup has also prevented FCC Commissioner Jonathan Adelstein from moving to the Rural Utilities Service (RUS). The FCC is current ly being run by interim Chairman Michael Copps, who’s been focusing most of his time on the transition to digital-only television. Though he has mostly acted as a caretaker, Copps has teed up a few is sues, including studies on increasing diversity in me dia ownership and a new national broadband plan. Baker is the daughter-in-law of former Secretary of State James Baker. She formerly ran the Commerce Department’s National Telecommunications and In formation Administration (NTIA). There was some question about whether she would be nominated since she headed the government’s effort to give out coupons for converter boxes needed to keep older TV sets working after the digital transition. Problems with that coupon program resulted in a four-month delay in the transition, according to WSJ. BloostonLaw contacts: Hal Mordkofsky, Ben Dickens, Gerry Duffy, and John Prendergast. |
INSIDE THIS ISSUE - Acting Chairman Copps sends rural broadband report to Congress.
- FCC approves NECA’s proposed modifications to average schedule formulas for interstate access services.
- FCC seeks to fix omission in 4.9 GHz rules.
- D.C. Circuit affirms on exclusivity pacts between cable companies, apartment buildings.
- VITAL MEETINGS & DEADLINES
|
Acting Chairman Copps Sends Rural Broadband Report To Congress As required by the 2008 Farm Bill, Acting FCC Chairman Michael Copps has submitted a report to Congress titled Bringing Broadband to Rural America: Report on a Rural Broadband Strategy. “I believe the Commission should do more such reports for Congress—not establishing policies that require Commission approval—but putting forth recommendations, ideas, and options to advise Congress, government, and the public as they consider these important issues,” Copps said. “I look forward to continuing to work on these issues with my colleagues and Congress and trust that this Report will help inform the discussion and provide a building block as the Com mission develops its national broadband plan.” In light of all this, the Report makes the following recommendations: Coordination of Rural Broadband Efforts. Increasing coordination—among federal agencies; Tribal, state, and local governments; and community groups and individuals—is a critical preliminary step towards ensuring that the various government programs accomplish their broadband goals and objectives in an efficient and effective way. - Improving Federal Agency Coordination. The federal interagency working group, formed by the Obama administration to coordinate the administration’s broadband agenda, should continue its ongoing efforts to enhance interagency coordination of rural broadband initiatives; and the Commission and other federal agencies should consider developing their own “rural broadband agendas” consistent with the national broadband plan.
- Other Coordination Efforts.
Tribal Coordination. To ensure a truly comprehensive strategy for addressing rural broadband deployment and adoption, it is important to maintain a continuing dialogue to address the unique issues presented in Tribal areas. As an integral part of their rural broadband initiatives:
(1) Federal agencies should consider how to maximize existing programs to improve coordination with Tribal governments; and
(2) The Commission should consult with Tribal governments pursuant to its Tribal Policy Statement in developing its national broadband plan and, in particular, in developing the aspects of that plan that affect broadband deployment and subscribership specifically on Tribal lands
State Coordination. The Commission and its state counterparts should take advantage of existing coordination mechanisms, such as the Federal-State Joint Conference on Advanced Services (Joint Conference). The Joint Conference should:
(1) Provide the Commission with its own recommendations for improving federal state coordination regarding rural broad band; (2) Include in its recommendations proposals for federal-state coordination to address and ameliorate the unique challenges presented to rural minority communities and persons with disabilities re siding in rural areas; and (3) Compile an inventory of successful state and local projects and “best practices.”
Coordination with Communities. In order to be successful in coordinating existing federal programs concerning rural broadband or rural initiatives, it is also critical that the federal government collaborate and coordinate with community and advocacy organizations in rural areas. The minority, disability, and low-income communities in rural areas face particular challenges. Federal agencies should work closely with organizations:
(1) To help ensure that all members of minority groups residing in rural areas have access to robust and affordable broadband services and that minority owned businesses participate fully in the buildout of broadband infrastructure in those areas. (2) Representing persons with disabilities to help ensure that they have afford able access to broadband services capable of supporting the full array of applications responsive to their needs. (3) That serve low-income residents to ensure the opportunities that affordable broadband offers this community do not go unrealized.
- Streamlining and Improving Existing Federal Programs. All relevant federal agencies should review their programs to identify what internal barriers, if any, may be making rural broadband deployment more difficult.
- Promoting Efficient Use of Government Funds and Resources. Federal agencies should review their non-broadband-related pro grams that involve rural issues to assess whether those programs provide opportunities to pro mote rural broadband deployment.
- Coordinating Program Criteria. So that dissimilar definitions and criteria across related or complementary programs do not unnecessarily hinder interagency coordination, federal agencies involved in rural broadband should coordinate key terminology (e.g., rural) across pro grams, consistent with their legislative mandates.
- Government Websites. One barrier to rural broadband deployment and adoption is a lack of easily-accessible and coordinated information about government resources available for promoting broadband. To help address this problem, the Report recommends that the Commission expand its website to include a comprehensive set of links to all federal government pro grams related to rural broadband. The Report also suggests expanding the Commission’s and USDA’s existing “Broadband Opportunities for Rural America” website to include a comprehensive list of all federal government programs related to rural broadband.
Assessing Broadband Needs. Congress directed that this Report make recommendations “to address both short and long-term needs assessments” for rural broadband. The Report does this by addressing the challenges of rural broadband today and the needs of rural broadband going forward. - Technological Considerations. Every rural area presents its own special challenges, and a particular technological solution may be well suited to one situation and poorly-suited to another. Decision makers therefore should proceed on a technology-neutral basis—by considering the attributes of all potential technologies—in selecting the technology or technologies to be deployed in a particular rural area.
- Information on Broadband Availability. One significant challenge to ubiquitous broadband deployment in rural areas is obtaining accurate information on broadband service and infrastructure availability and the demand for broadband services. Pursuant to the Broadband Data Improvement Act (BDIA) and the Recovery Act, the Commission should work to collect this information to better inform decision making, in coordination with the administration, and Tribal and state governments.
- Broadband Mapping. In the rural context, broadband mapping is a necessary tool for identifying and tracking broadband service availability and infrastructure deployment, yet it is only as accurate and reliable as its underlying data. Pursuant to the Recovery Act and the BDIA, the Commission and the administration should continue their efforts to coordinate federal, Tribal, state, local, and private mapping efforts.
- Stimulating and Sustaining Demand for Broadband. Various factors may affect demand for broadband services in rural areas, including a lack of knowledge regarding the benefits of Internet access, lack of training on how to use a computer, socioeconomic and demographic factors, and affordability. To help stimulate and sustain demand for broadband services in rural areas, both public and private entities should consider developing consumer education and training initiatives, broadband affordability programs, and other incentives to achieve sustainable penetration rates.
- Addressing Network Costs. Relying on market forces alone will not bring robust and affordable broadband services to all parts of rural America. Therefore, all levels of government should explore ways to help overcome the high costs of rural broadband deployment.
Overcoming Challenges to Rural Broadband Deployment. Because the national broadband plan is not due until February 2010, it is prudent for the Commission to identify any pending and proposed Commission proceedings affecting rural broadband. These pending proceedings include universal service reform, network openness, spectrum access, middle mile/special access reform, intercarrier compensation, access to poles and rights of way, tower siting, and video programming proceedings. The Commission should consider all these proceedings as it develops the national broadband plan, balancing the desire to resolve these matters with the need to address rural broadband in the context of a much broader and forward-looking national broadband plan. Chairman Copps continues to support comprehensive reform of the universal service program. “It is of great interest to Congress, consumers, industry, and the Commission. I have long held the view that it is time for universal service to meet the communications challenge of the 21st century—broadband deployment—just as it did the communications challenge of the 20th century—telephone service.” Status Report. To help inform Congress of any needed changes to the recommendations in this Report in light of additional efforts to address rural broadband issues, including the completion of the national broadband plan, the next Commission Chairman should consider completing a status report on rural broadband approximately one year from now. BloostonLaw contacts: Hal Mordkofsky, Ben Dickens, Gerry Duffy, and John Prendergast. FCC APPROVES NECA’s PROPOSED MODIFICA TIONS TO AVERAGE SCHEDULE FORMULAS FOR INTERSTATE ACCESS SERVICES: The FCC has ap proved the National Exchange Carrier Association’s (NECA’s) proposed modifications to the current average schedule formulas to become effective July 1, 2009. Ac cording to the FCC, NECA’s filing was submitted in accordance with Commission rules that require NECA to submit proposed modifications to the average schedule formulas annually or to certify that no modifications are warranted. NECA proposes to revise the formulas for average schedule interstate settlement disbursements in connection with the provision of interstate access services. NECA notes that factors driving this year’s filing include slow account growth and significant reductions in some access demand elements. NECA proposes to “change the way settlements are calculated for tandem switching and line haul circuit termination costs to reflect significant cost efficiencies associated with high ratios of circuits per access line.” NECA proposes “to continue to limit access minute volumes and line haul circuit counts that would be eligible for average schedule settlements.” NECA also proposes to provide “a special access settlement method adjustment for study areas that provide digital subscriber line (DSL) outside NECA’s tariff, to keep their settlements for non-DSL services at parity with other study areas.” NECA explains that “study areas with high ratios of inter-toll circuits per access line or of line haul circuit terminations per access line will realize significant settlement reductions, while study areas with very low ratios will experience increases in settlements.” NECA calculates that the majority of other companies will have small settlement increases, assuming demand levels remain constant year-to-year, although the effects on individual average schedule companies will vary de pending on each company’s size and demand characteristics. Overall, NECA proposes formula changes that would increase settlement rates by about 2.09 percent, given constant demand. NECA requests that these modifications take effect on July 1, 2009, and remain in effect through June 30, 2010. The FCC reviewed NECA’s filing and found that its proposed formula revisions are reasonable. Accordingly, the formulas will become effective July 1, 2009, and remain in effect through June 30, 2010. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. FCC SEEKS TO FIX OMISSION IN 4.9 GHz RULES: The FCC has adopted a Further Notice of Proposed Rulemaking (FNPRM) to address an apparent inadvertent omission of a Commission rule that provided an exemption to 4.9 GHz band applicants from certified frequency coordination. It seeks comment on reinstating the omitted language into the Commission's part 90 rules. When the Commission originally crafted the 4.9 GHz rules, it did not require frequency coordinators to certify applications because “all frequencies will be shared among licensees, and adjacent and co-located licensees are required to cooperate and coordinate in use of the spectrum.'' Accordingly, the Commission codified a frequency coordination exemption for applications for frequencies in the 4940-4990 MHz band (4.9 GHz exemption). The 4.9 GHz exemption appeared in the Federal Register entry for the 4.9 GHz Third Report and Order, 68 FR 38635, June 30, 2003, as well as the 2003 and 2004 editions of the Commission's rules on Sec. 90.175(j). However, in 2005 and subsequent editions of the Code of Federal Regulations, the exemption for 4.9 GHz applications was omitted. The omission of the 4.9 GHz exemption appears to have occurred inadvertently as a result of a rulemaking in 2004. On February 10, 2004, the Commission released a 5.9 GHz Report and Order, 69 FR 46438, August 3, 2004, to revise, inter alia, Sec. 90.175(j) “by adding a new subparagraph (17)'' to exempt from frequency coordination “applications for DSRCS [Dedicated Short-Range Communications Service] licensees (as well as registrations for Roadside Units) in the 5850-5925 GHz band” (DSRCS exemption). However, the 2003 Code of Federal Regulations, which was in effect at the time the 5.9 GHz Report and Order was released, already contained seventeen exemptions in Sec. 90.175(j). Because the 5.9 GHz Report and Order stated that it was adding a new subparagraph, the FCC tentatively concludes that the Commission did not intend to delete the 4.9 GHz exemption, then listed as Sec. 90.175(j)(17). The FCC bases this tentative conclusion on the lack of any corresponding discussion in the 5.9 GHz Report and Order relating to such a deletion, or any evidence of such an intention in subsequent proceedings. Comments in this WP Docket No. 07-100 proceeding are due July 20, 2009. Reply comments are due August 19, 2009. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino. D.C. CIRCUIT AFFIRMS FCC BAN ON EXCLUSIVITY PACTS BETWEEN CABLE COMPANIES, APART MENT BUILDINGS: The U.S. Court of Appeals for the District of Columbia Circuit has ruled that the FCC acted well within the bounds of Section 628 of the Communications Act and general administrative law in finding that exclusivity agreements between cable companies and owners of apartment buildings and other multi-unit developments have an anti-competitive effect on the cable market. In National Cable & Telecommunications Association v. FCC, the D.C. Circuit said that the Commission believes that these deals—which involve a cable company exchanging a valuable service like wiring a building for the exclusive right to provide service to the residents—may be regulated under section 628 of the Communications Act as cable company practices that significantly impair the ability of their competitors to deliver programming to consumers. The Commission thus forbade cable operators not only from entering into new exclusivity con tracts, but also from enforcing old ones. Petitioners, associations representing cable operators and apartment building owners, argue that the Commission exceeded its statutory authority, arbitrarily departed from precedent, and otherwise violated the Administrative Procedure Act. The court concluded “Having carefully considered the parties’ excellent submissions, we disagree and conclude that the Commission acted well within the bounds of both section 628 and general administrative law.” Blooston Law contact: Gerry Duffy. JUNE 30: ANNUAL ICLS USE CERTIFICATION. Rate of return carriers and CETCs must file a self-certification with the FCC and the Universal Service Administrative Company (USAC) stating that all Interstate Common Line Support (ICLS) and Long Term Support (LTS) will be used only for the provision, maintenance, and upgrading of facilities and services for which the support is in tended. In other words, carriers are required to certify that their ICLS and LTS support is being used consistent with Section 254(e) of the Communications Act. Failure to file this self-certification will preclude the carrier from receiving ICLS support. We, therefore, strongly recommend that clients have BloostonLaw submit this filing and obtain an FCC proof-of-filing receipt for client records. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. JULY 10: DTV EDUCATION REPORT. New 700 MHz licensees from Auction No. 73 are required to file a report with the FCC concerning their efforts to educate consumers about the upcoming transition to digital television (DTV). Last summer, we explained that the FCC’s Part 27 rules require 700 MHz licensees that won licenses in Auction No. 73 to file quarterly reports on their DTV consumer outreach efforts through the Spring of 2009. However, in an apparent contradiction, the same rules do not impose any substantive consumer education requirements on 700 MHz license holders. This situation has not changed. The reporting rule simply states that “the licensee holding such authorization must file a report with the Commission indicating whether, in the previous quarter, it has taken any outreach efforts to educate consumers about the transition from analog broadcast television service to digital broadcast television service (DTV) and, if so, what specific efforts were undertaken.” Many licensees may not have initiated 700 MHz service as of yet. However, to the extent they are also an Eligible Telecommunications Carrier (ETC) and recipient of federal USF funds, separate FCC rules found in 47 C.F.R. Part 54 (Universal Service) require ETCs to send monthly DTV transition notices to all Lifeline/Link-Up customers (e.g., as part of their monthly bill), and to include information about the DTV transition as part of any Lifeline or Link-Up publicity campaigns until June 30, 2009. BloostonLaw contacts: Hal Mordkofsky and Cary Mitchell. JULY 20: FCC FORM 497, LOW INCOME QUARTERLY REPORT. This form, the Lifeline and Link-Up Work sheet, must be submitted to the Universal Service Administrative Company (USAC) by all eligible telecommunications carriers (ETCs) that request reimbursement for participating in the low-income program. The form must be submitted by the third Monday after the end of each quarter. It is available at: www.universalservice.org. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. JULY 31: FCC FORM 507, UNIVERSAL SERVICE QUARTERLY LINE COUNT UPDATE. Line count up dates are required to recalculate a carrier's per line universal service support, and is filed with the Universal Service Administrative Company (USAC). This information must be submitted on July 31 each year by all rate of-return incumbent carriers, and on a quarterly basis if a competitive eligible telecommunications carrier (CETC) has initiated service in the rate-of-return incumbent carrier’s service area and reported line count data to USAC in the rate-of-return incumbent carrier’s service area, in order for the incumbent carrier to be eligible to receive Interstate Common Line Support (ICLS). This quarterly filing is due July 31 and covers lines served as of December 31, 2007. Incumbent carriers filing on a quarterly basis must also file on September 30 (for lines served as of March 31, 2008); December 30 (for lines served as of June 30, 2008), and March 31, 2009, for lines served as of September 30, 2008).. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. JULY 31: FCC FORM 525, COMPETITIVE CARRIER LINE COUNT QUARTERLY REPORT. Competitive eligible telecommunications carriers (CETCs) are eligible to receive high cost support if they serve lines in an incumbent carrier’s service area, and that incumbent carrier receives high cost support. CETCs are eligible to receive the same per-line support amount received by the incumbent carrier in whose study area the CETC serves lines. Unlike the incumbent carriers, CETCs will use FCC Form 525 to submit their line count data to the Universal Service Administrative Company (USAC). This quarter ly report must be filed by the last business day of March (for lines served as of September 30 of the previous year); the last business day of July (for lines served as of December 31 of the previous year); the last business day of September (for lines served as of March 31 of the current year); and the last business day of December (for lines served as of June 30 of the current year). CETCs must file the number of working loops served in the service area of an incumbent carrier, disaggregated by the incumbent carrier’s cost zones, if applicable, for High Cost Loop (HCL), Local Switching Support (LSS), Long Term Support (LTS), and Interstate Common Line Support (ICLS). ICLS will also require the loops to be reported by customer class as further described below. For Interstate Access Support (IAS), CETCs must file the number of working loops served in the service area of an incumbent carrier by Unbundled Network Element (UNE) zone and customer class. Working loops provided by CETCs in ser vice areas of non-rural incumbents receiving High Cost Model (HCM) support must be filed by wire center or other methodology as determined by the state regulatory authority. CETCs may choose to complete FCC Form 525 and submit it to USAC, or designate an agent to file the form on its behalf. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. JULY 31: REPORT OF EXTENSION OF CREDIT TO FEDERAL CANDIDATES. This report (in letter format) must be filed by January 30 and July 31 of each year, but ONLY if the carrier extended unsecured credit to a candidate for a Federal elected office during the reporting period. BloostonLaw contacts: Hal Mordkofsky, John Prendergast, and Richard Rubino. AUGUST 1: FTC BEGINS ENFORCEMENT OF RED FLAG RULES. The Federal Trade Commission (FTC) has delayed enforcement of the “Red Flag” Rules for 90 days until August 1, 2009, to give creditors and financial institutions additional time to implement identity theft programs. Under the new rules, all businesses that maintain a creditor-debtor relationship with customers, including virtually all telecommunications carriers (but other companies as well), must adopt written procedures designed to detect the relevant warning signs of identity theft, and implement an appropriate response. The Red Flag compliance program was in place as of November 1, 2008. But the FTC will not enforce the rules until Au gust 1, 2009, meaning only that a business will not be subject to enforcement action by the FTC if it de lays implementing the program until August 1. The FTC announcement does not affect other federal agencies’ enforcement of the original Nov. 1, 2008, compliance deadline for institutions subject to their oversight. Other liabilities may be incurred if a violation occurs in the meantime. The requirements are not just binding on telcos and wireless carriers that are serving the public on a common carrier basis. They also apply to any “creditor” (which includes entities that defer payment for goods or services) that has “covered accounts” (ac counts used mostly for personal, family or household purposes). This also may affect private user clients, as well as many telecom carriers’ non-regulated affiliates and subsidiaries. BloostonLaw has prepared a Red Flag Compliance Manual to help your company achieve compliance with the Red Flag Rules. Please contact Gerry Duffy (202-828-5528) or Mary Sisak (202-828-5554) with any questions or to request the manual. AUGUST 3: FCC FORM 499-Q, TELECOMMUNICATIONS REPORTING WORKSHEET. All telecommunications common carriers that expect to contribute more than $10,000 to federal Universal Service Fund (USF) support mechanisms must file this quarterly form. (Normally this form is due on August 1, but because August 1 falls on a Saturday this year, the next business day is Monday, August 3.) This filing requirement also applies to certain Private Mobile Radio Service (PMRS) licensees, such as for-profit paging and messaging, dispatch and two-way mobile radio services. The FCC has modified this form in light of its recent decision to establish interim measures for USF contribution assessments. The form contains revenue information from the prior quarter plus projections for the next quarter. Form 499-Q relates only to USF contributions. It does not relate to the cost recovery mechanisms for the Telecommunications Relay Service (TRS) Fund, the North American Numbering Plan Administration (NANPA), and the shared costs of local number portability (LNP), which are covered in the annual form (Form 499-A) that was due April 1. For-profit private radio service providers that are “de minimis” (those that contribute less than $10,000 per year to the USF) do not have to file the 499-A or 499-Q. However, they must fill out the form and retain the relevant calculations as well as documentation of their contribution base revenues for three years. De minimis telecom carriers must actually file the Form 499A, but not the 499Q. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. AUGUST 3: FCC FORM 502, NUMBER UTILIZATION AND FORECAST REPORT: Any wireless or wireline carrier (including paging companies) that have received number blocks--including 100, 1,000, or 10,000 number blocks—from the North American Numbering Plan Administrator (NANPA), a Pooling Administrator, or from another carrier, must file Form 502 by August 3. (Normally, this filing would be due August 1, but this year August 1 falls on a Saturday, and FCC rules require the filing be submitted the first business day thereafter.) Carriers porting numbers for the purpose of transferring an established customer’s service to another service provider must also report, but the carrier receiving numbers through porting does not. Resold services should also be treated like ported numbers, meaning the carrier transfer ring the resold service to another carrier is required to report those numbers but the carrier receiving such numbers should not report them. New this year is that report ing carriers are required to include their FCC Registration Number (FRN). Reporting carriers file utilization and forecast reports semiannually on or before February 1 for the preceding six-month reporting period ending December 31, and on or before August 1 for the preceding six month reporting period ending June 30. BloostonLaw contacts: Ben Dickens, Gerry Duffy, and Mary Sisak. VITAL MEETINGS & DEADLINES June 3 – FCC open meeting. June 4 – Deadline for comments on FY 2009 regulatory fees (MD Docket No. 09-65). June 8 – Deadline for reply comments on NOI to refresh record on non-rural USF support mechanism (WC Dock et No. 05-337). June 8 – Deadline for comments on NOI seeking comment on developing national broadband plan (GN Docket No. 09-51). June 11 – Deadline for reply comments on FY 2009 regulatory fees (MD Docket No. 09-65). June 12 – DTV Transition. June 13 – DTV Analog Nightlight program begins and runs for 30 days until July 12. June 15 – Deadline for reply comments on conservation groups’ request for FCC action on antenna structures (WT Docket Nos. 08-61, 03-187). June 15 – Deadline for comments on 14th Annual Report on CMRS Competition (WT Docket No. 09-66). June 16 – Deadline for ILECs filing annual access tariffs on 15 days’ notice (carriers proposing to increase any of their rates). June 19 – Deadline for both paper and electronic copies of applications for FY 2009 RUS Community Connect Grants for broadband projects. June 23 – Deadline for petitions to suspend or reject annual access tariffs filed on 15 days’ notice (by carriers proposing to increase any of their rates). June 24 – Deadline for ILECs filing annual access tariffs on seven day’s notice (carriers proposing to decrease all of their rates). June 26 – Deadline for petitions to suspend or reject annual access tariffs filed on seven day’s notice (by carriers proposing to decrease all of their rates). June 26 – Deadline for replies to petitions to suspend or reject annual access tariffs filed on 15 days’ notice (by carriers proposing to increase any of their rates). June 29 – Deadline for replies to petitions to suspend or reject annual access tariffs filed on seven day’s notice (by carriers proposing to decrease all of their rates). June 29 – Deadline for reply comments on 14th Annual Report on CMRS Competition (WT Docket No. 09-66). June 30 – DTV Consumer Education Initiative requirements expire. June 30 – Annual ICLS Use Certification is due. June 30 – Deadline for reply comments on Supplemental NOI regarding video competition report (2008 data) (MB Docket No. 07-269). |
The Model 640 DAPT-XTRA Paging Terminal is a cost effective solution for small to medium-sized systems and private organizations offering a paging service based on bureau-type operator paging and/or direct telephone access. The 640 supports up to 1,500 users with up to 4 telephone lines. It also supports voice paging, voice prompts, talkback paging, and alphanumeric paging.
Zetron's Remote Monitoring equipment provides monitoring and notification of unusual conditions and status changes. Messages are automatically transmitted over a radio or a public address system. Notification can be sent via speaker or radio announcement, telephone, cellular phone, or paging.
NEW ALERT AND RINGTONE AMPLIFIER 
Editors Note: This article first appeared in the January/February 2009 IMSA Journal, Volume XLVII, Number 1.
II 1 G EEx ia IIA T4 
