Selected portions of the BloostonLaw Telecom Update, and/or the BloostonLaw Private Users Update — newsletters from the Law Offices of Blooston, Mordkofsky, Dickens, Duffy & Prendergast, LLP — are reproduced in this section with the firm’s permission.
|BloostonLaw Telecom Update||Vol. 18, No. 29||July 15, 2015|
FCC Highlights Obligation of Carriers to Protect Personal Information of Customers
The FCC Enforcement Bureau has entered into a $3.5 million settlement with TerraCom, Inc. and YourTel America, Inc., resolving an investigation which found that the companies "failed to protect the confidentiality of proprietary information that they received from customers applying to demonstrate eligibility for their low-income Lifeline phone services, including sensitive personal information such as names, addresses, dates of birth, full or partial Social Security numbers, and driver’s licenses." According to the FCC, the companies’ vendor stored the proprietary information "in clear, readable text on servers that were accessible over the Internet, and the data was not password protected or encrypted." This resulted in a data breach which exposed their customer’s personal information to unauthorized individuals.
Every company should review its policies and practices to ensure that the customers' CPNI and "sensitive personal information" is secure. This includes ensuring that the company and all of its vendors do not store proprietary information in clear, readable text on servers that are accessible over the Internet, and that data is password protected or encrypted. BloostonLaw is available to assist companies with this review and with the development of appropriate procedures.
The FCC found that the "failure to reasonably secure customers’ proprietary information, including their personal data, violates a carrier’s duty under Section 222 of the Communications Act, and also constitutes an unjust and unreasonable practice in violation of Section 201 of the Act." The FCC states that it expects telecommunications carriers to take “every reasonable precaution” to protect their customers’ data.
In addition to paying a $3.5 million civil penalty, the companies must develop and implement a compliance plan to ensure appropriate procedures are incorporated into their business practices to protect consumers against similar data breaches in the future. According to the FCC, "TerraCom and YourTel will be required to improve their privacy and data security practices by: (i) designating a senior corporate manager who is a certified privacy professional; (ii) conducting a privacy risk assessment; (iii) implementing a written information security program; (iv) maintaining reasonable oversight of third party vendors; (v) implementing a data breach response plan; and (vi) providing privacy and security awareness training to employees. The companies also will "notify all consumers whose information was subject to unauthorized access, provide complimentary credit monitoring services for all affected individuals, and undertake additional measures to mitigate any potential harm to consumers."
The FCC states that in the absence of material new evidence relating to this matter, it will not set for hearing the question of the companies' "basic qualifications to hold or obtain any Commission license or authorization.”
FCC Delays Vote on Incentive Auction Procedures Notice, Mobile Spectrum Holdings Recon Order
In a Public Notice released late on Wednesday afternoon, just before the BloostonLaw Telecom Update went to press, the FCC deleted two significant items related to the Broadcast Incentive Auction from its agenda for the July 16th Open Meeting. Items pulled from the agenda include votes on the Incentive Auction Procedures Public Notice, and an Order on Reconsideration addressing petitions for reconsideration of the Mobile Spectrum Holdings Report and Order. A vote on proposed revisions to the Commission’s Competitive Bidding and Designated Entity (DE) rules remains on the agenda.
Removal of the Incentive Auction Procedures PN from the agenda was not unexpected. House Energy and Commerce Committee leaders wrote to the FCC on Tuesday asking that Chairman Tom Wheeler postpone Thursday’s vote on incentive auction procedures. Committee Chair Fred Upton (R-Mich) and Communications and Technology Subcommittee Chairman Greg Walden (R-Ore) expressed concern about the Commission’s “last-minute addition of significant data into the record” less than a week before the scheduled vote.
Upon release of the letter, Upton and Walden commented, “Here we go again. Like a broken record, we have heard the FCC leadership pledge repeatedly to improve process while continuing to find new ways to keep the public in the dark. Had the commission heeded the advice of commenters and released these data weeks ago, we would be lauding the commission today for its commitment to debate and a complete record. But when the commission acts to withhold data until the eleventh hour, it is going out of its way to keep the public and relevant stakeholders — including the commissioners — out of the process."
The data in question relates to spectrum clearing target determination simulations that the Commission’s staff has performed to evaluate various incentive auction band repacking scenarios. The repacking process is extraordinarily complex, and it has significant impact on broadcasters’ decisions whether or not to relinquish their spectrum. FCC Incentive Auction Task Force staff released data from just a handful of clearing scenarios by way of a docket filing at close of business last Friday. Concurrent with releasing this data, the Incentive Auction Task Force invited interested parties to file comments and the FCC issued a rare waiver of the Sunshine period prohibition so comments could be filed right up until the night before the Commission meeting.
Despite the postponement, FCC Chairman Tom Wheeler expressed optimism that the Incentive Auction could still take place in early 2016. "In the spirit of cooperation that has marked our work together on the incentive auctions, I am today postponing Commission consideration of this order and the related reconsideration of the mobile spectrum holdings order until the Commission's next regularly scheduled meeting on August 6," wrote Wheeler in a letter responding to Reps. Upton and Walden. "I believe that even with this delay we will be able to stay on course for the first quarter of 2016."
The broadcast industry has argued that running just a few post-incentive auction repack simulations is insufficient. An ex parte letter from the National Association of Broadcasters criticized the Commission for the meager, and last minute, data dump.
“The FCC released only two simulations for each of three spectrum clearing targets, wrote NAB General Counsel Rick Kaplan. “There is little to be gained from analyzing a mere six simulations. By contrast, last summer the FCC released 100 repacking simulations. This information enabled outside parties, including NAB, to draw meaningful conclusions concerning, for example, the likelihood of certain outcomes. In this instance, releasing only two simulations per clearing target is akin to asking a person to accurately predict the National League pennant winner by watching only two games from the 162-game Major League Baseball schedule.”
NAB also criticized the Commission’s staff for failing to adequately explain the assumptions made in its handful of simulations, as well as for failing to analyze the effect of putting TV stations in the duplex gap ( i.e., within the new wireless band plan) against other interference proposals.
“Ultimately, the information released late Friday night suggests deep problems with the auction or a significant lack of transparency, or both,” wrote Kaplan.
Chairman Wheeler also postponed the Commission’s vote on whether to expand the size of the “spectrum reserve,” a block of the 600 MHz spectrum that the Commission has proposed to set aside for bidding by smaller carriers. The current reserve is capped at 30 MHz, but competitive carriers like Sprint, T-Mobile and Dish have led an aggressive campaign seeking to have the Commission increase the reserve to at least 40 MHz.
In a written statement yesterday expressing frustration over the FCC’s delay and lack of transparency, Commissioner Ajit Pai offered his own proposals for how the FCC should proceed.
“I would like to offer a couple of suggestions for a path forward,” wrote Pai. “First, during the week of July 27, the Commission should hold an en banc hearing to consider issues pertaining to band plan variability and the appropriate placement of broadcast stations, if necessary, in the wireless portion of the 600 MHz band. These issues deserve a thorough public airing. Let’s invite broadcasters, wireless carriers, and unlicensed advocates to testify. Witnesses should have the opportunity to share their views, and Commissioners should have ample opportunity to ask questions. Let’s see where there is disagreement and try to forge common ground.”
“Second, the Commission should immediately release all of the data pertaining to the staff’s simulations. The Commission should also conduct additional simulations and release all of the data pertaining to those simulations as well. Our office has heard numerous complaints from stakeholders that too little data has been released and that more simulations are needed. In particular, we should not make decisions on a future band plan based on only two simulations per clearing target. Rather, we should be able to evaluate the wide range of possible outcomes for each clearing target.”
We will keep our clients apprised of developments once the items from the July Open Meeting become available.
FCC Issues TCPA Omnibus Declaratory Ruling
The FCC has released a Declaratory Ruling and Order clarifying numerous issues concerning the application of the Telecommunications Consumer Protection Act (TCPA) and providing guidance on whether certain conduct violates the TCPA. (CG Docket No. 02-278, WC Docket No. 07-135). Among the issues addressed by the FCC are the following:
- Any equipment that has the requisite “capacity” to dial random and sequential numbers is an autodialer and is therefore subject to the TCPA. Callers cannot avoid obtaining consumer consent for a robocall simply because they are not “currently” or “presently” dialing random or sequential phone numbers. The FCC acknowledges, however, that the definition of “autodialer” does not extend to every piece of malleable and modifiable dialing equipment that conceivably could be considered to have some capacity, however small, to store and dial telephone numbers. For example, a handset with the mere addition of a speed dial button is not an autodialer. Further, there must be more than a theoretical potential that the equipment could be modified to satisfy the “autodialer” definition. Thus, the FCC states that although it might be theoretically possible to modify a rotary-dial phone to such an extreme that it would satisfy the definition of autodialer, "such a possibility is too attenuated for us to find that a rotary-dial phone has the requisite ’capacity‘ and therefore is an autodialer."
- Calls to reassigned wireless numbers violate the TCPA when a previous subscriber, not the current subscriber or customary user, provided the prior express consent on which the call is based. The consumer assigned the telephone number dialed and billed for the call, or the non-subscriber customary user of a telephone number included in a family or business calling plan can give prior express consent to be called at that number. However, where a caller believes he has consent to make a call and does not discover that a wireless number had been reassigned prior to making or initiating a call to that number for the first time after reassignment, the FCC finds that liability should not attach for that first call, but the caller is liable for any calls thereafter. Further, the caller, and not the called party, bears the burden of demonstrating: (1) that he had a reasonable to basis to believe he had consent to make the call, and (2) that he did not have actual or constructive knowledge of reassignment prior to or at the time of this one-additional-call window we recognize as an opportunity for callers to discover reassignment.
- Internet-to-phone text messages require consumer consent.
- Text messages are “calls” subject to the TCPA, as previously determined by the Commission. Consumer consent is required for text messages sent from text messaging apps that enable entities to send text messages to all or substantially all text-capable U.S. telephone numbers, including through the use of autodialer applications downloaded or otherwise installed on mobile phones.
- The Communications Act and the FCC's rules do not prohibit carriers or Voice over Internet Protocol (VoIP) providers from implementing consumer-initiated call-blocking technology that can help consumers stop unwanted robocalls.
- With regard to collect call services, the FCC clarifies that, where a caller provides the called party’s phone number to a collect call service provider and controls the content of the call, he is the maker of the call rather than the collect-call service provider who connects the call and provides information to the called party that is useful in determining whether he or she wishes to continue the call.
- Whether a person who offers a calling platform service for the use of others has knowingly allowed its client(s) to use that platform for unlawful purposes may be a factor in determining whether the platform provider is so involved in placing the calls as to be deemed to have initiated them.
- Collect calling service providers that use prerecorded messages, on a single call-by-call basis, to provide call set-up information when attempting to connect a collect call to a residential or wireless telephone number may do so under the TCPA without first obtaining prior express consent from the called party. The person who dials the number of the called party or the number of a collect calling service provider in order to reach the called party, rather than the collect calling service provider who simply connects the call, “makes” the call for purposes of the TCPA.
- The FCC clarifies that the fact that a consumer’s wireless number is in the contact list on another person’s wireless phone, standing alone, does not demonstrate consent to autodialed or prerecorded calls, including texts.
- The FCC clarifies that a called party may revoke consent at any time and through any reasonable means. A caller may not limit the manner in which revocation may occur. Further, if any question arises as to whether prior express consent was provided by a call recipient, the burden is on the caller to prove that it obtained the necessary prior express consent.
- The FCC exempts from the TCPA’s consumer consent requirements, messages about time-sensitive financial and healthcare issues, if a long list of conditions are followed. Calls intended to prevent fraudulent transactions or identify theft, calls involving data security breaches and calls conveying measures consumers may take to prevent identity theft following a data breach are exempt.
Please contact the firm if you have questions about whether specific conduct of your company complies with the TCPA and the FCC's Declaratory Ruling.
FCC Releases Fact Sheet on Proposed Technology Transition Reforms
On July 10, the FCC issued a Fact Sheet providing high-level information on two items that Chairman Wheeler is planning to circulate to the other Commissioners and which will be voted upon at next month’s Open Meeting.
The first item is a Report and Order that “would help ensure consumers have the information and tools necessary to maintain available communications at home during an emergency.” More specifically, providers of modern, non-copper based landline home phone service would be required to a) ensure that “a technical solution” for 8 hours of standby backup power is available for consumers to purchase, either directly or from a third-party retailer, at the point of sale and b) offer an option for 24 hours of standby backup power within three years.
The second item is a Report and Order, Order on Reconsideration and Further Notice of Proposed Rulemaking intended to protect consumers as copper networks are replaced by next-generation networks by:
- Requiring that consumers be notified of plans to retire copper networks approximately six months in advance for non-residential customers and three months in advance for residential customers.
- Defining “retirement” in such a way to prevent retirement of networks by neglect (sometimes referred to as “de facto” retirement).
- Requiring notice to interconnecting carriers for retirement of all parts of the copper network that are critical to providing their customers with service.
- Retaining carrier flexibility to retire copper networks in favor of newer facilities without prior Commission approval as long as no service is discontinued, reduced, or impaired.
The second item also attempts to preserve competition in the enterprise market by:
- Requiring, as an interim measure, that replacement services be offered to competitive providers at rates, terms and conditions that are reasonably comparable to those of the legacy services.
- Clarifying that a carrier that plans to discontinue a service that has only carrier customers must still follow the statutory process for discontinuance if the action would negatively impact retail users served by those carrier customers.
It also tentatively concludes that both consumers and industry would be served by clarifying these standards by which replacement and legacy services are evaluated when considering Section 214 discontinuance, and seeks comment on criteria which include:
- Support for 911 services and call centers
- Network capacity and reliability
- Quality of both voice service and Internet access
- Interoperability with devices and services, such as alarm services and medical monitoring
- Access for people with disabilities, including compatibility with assistive technologies
- Network security in any IP-supported network that is comparable to the legacy network
- Coverage throughout the service area, either by the substitute network or via service from other provider
Law & Regulation
Lifeline Order on Reconsideration Effective Date Established; Document Retention Requirements
On July 14th, the FCC’s Lifeline Order on Reconsideration and Second Report and Order appeared in the Federal Register, establishing an effective date of August 13th for the rules adopted therein.
Most notably, as of the effective date, all ETCs must retain documentation demonstrating subscriber income-based or program-based eligibility for participation in the Lifeline program for the purposes of production during audits or investigations or to the extent required by NLAD processes, including the dispute resolution processes that require verification of identity, address, or age of subscribers. ETCs must also retain documentation that was reviewed to verify subscriber information for the NLAD dispute resolution process. Such information, of course, must be protected under Section 222 of the Communications Act.
Other revisions include a uniform “snapshot” date each month for Lifeline providers to calculate their number of subscribers for the purpose of reimbursement (the first day of the month); elimination of the requirement that incumbent local exchange carriers must resell retail Lifeline-discounted service; and limits for reimbursement for Lifeline service to Lifeline providers directly serving Lifeline customers.
House Subcommittee Asks FCC to Address Nationwide Wireless Number Portability
On July 9, members of the House Communications and Technology Subcommittee sent a letter to Chairman Wheeler asking the FCC to ensure nationwide wireless number portability for all providers. According to the letter, the members are concerned that customers hoping to switch to non-nationwide wireless carriers may be unable to port-in their numbers under the existing rules, and said this distinction places non-nationwide providers at a competitive disadvantage. The members urged the FCC to address the issue as soon as possible.
House Subcommittee Hearings on Broadband Investment Postponed
The House Energy and Commerce Communications and Technology Subcommittee hearing that Chairman Greg Walden (R-Ore.) announced on July 8 has been postponed to a date and time that have yet to be determined.
The purpose of the hearing is to discuss ways to improve the environment for investment in both fixed and mobile broadband. Witnesses have not yet been announced.
White House Unveils ConnectHome Low-Income Broadband Pilot Program
Today, the White House unveiled a new initiative aimed at providing high-speed internet to low-income families, dubbed ConnectHome. According to the official press release, the pilot program is launching in twenty-seven cities and one tribal nation and will initially reach over 275,000 low-income households.
In Google Fiber markets (including the ConnectHome cities of Atlanta, Durham, Kansas City, and Nashville), Google Fiber will offer $0 monthly home Internet service to residents in select public housing authority properties and will partner with community organizations on computer labs and digital literacy programming to bridge the digital divide, especially for families with K-12 students.
In select communities of Choctaw Tribal Nation, Cherokee Communications, Pine Telephone, Suddenlink Communications, and Vyve Broadband will work together to ensure that over 425 of Choctaw’s public housing residents have access to low-cost, high-speed internet.
In Seattle, and across its coverage footprint, CenturyLink will make broadband service available to Department of Housing and Urban Development (HUD) households, via its Internet Basics program, for $9.95 per month for the first year and $14.95 per month for the next four years.
In Macon, Meriden, Baton Rouge, and New Orleans, Cox Communications will offer home Internet service for $9.95 per month to eligible K-12 families residing in public housing authorities. As part of its existing ConnectED commitment, Sprint will work with HUD and the ConnectHome program to make its free wireless broadband Internet access service program available to eligible K-12 students living in public housing. This builds upon the free mobile broadband service previously committed to low-income students by AT&T and Verizon, for ConnectED.
Additionally, non-profit and private sector entities will assist in providing digital literacy and technology training resources. For example, Best Buy will offer HUD residents in select ConnectHome demonstration project cities, including Choctaw Tribal Nation, computer training and technical support as well as after-school technical training, for free, to students participating in ConnectHome at Best Buy Teen Centers in Atlanta, Los Angeles, New York City, San Antonio, and Washington, DC.
HUD will also begin a rulemaking that requires HUD-funded new residential construction and substantial rehabilitation projects to support broadband internet connectivity; provide communities with the flexibility to spend portions of their Choice Neighborhood Implementation Grants on local broadband initiatives and associated connectivity enhancements, among other things.
JULY 31: FCC FORM 507, UNIVERSAL SERVICE QUARTERLY LINE COUNT UPDATE. Line count updates 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, 2014. Incumbent carriers filing on a quarterly basis must also file on September 30 (for lines served as of March 31, 2015); December 30 (for lines served as of June 30, 2015), and March 31, 2016, for lines served as of September 30, 2015).
JULY 31: CARRIER IDENTIFICATION CODE (CIC) REPORTS. Carrier Identification Code (CIC) Reports must be filed by the last business day of July (this year, July 31). These reports are required of all carriers who have been assigned a CIC code by NANPA. Failure to file could result in an effort by NANPA to reclaim it, although according to the Guidelines this process is initiated with a letter from NANPA regarding the apparent non-use of the CIC code. The assignee can then respond with an explanation. (Guidelines Section 6.2). The CIC Reporting Requirement is included in the CIC Assignment Guidelines, produced by ATIS. According to section 1.4 of that document: At the direction of the NANPA, the access providers and the entities who are assigned CICs will be requested to provide access and usage information to the NANPA, on a semi-annual basis to ensure effective management of the CIC resource. (Holders of codes may respond to the request at their own election). Access provider and entity reports shall be submitted to NANPA no later than January 31 for the period ending December 31, and no later than July 31 for the period ending June 30. It is also referenced in the NANPA Technical Requirements Document, which states at 7.18.6: CIC holders shall provide a usage report to the NANPA per the industry CIC guidelines … The NAS shall be capable of accepting CIC usage reports per guideline requirements on January 31 for the period ending December 31 and no later than July 31 for the period ending June 30. These reports may also be mailed and accepted by the NANPA in paper form. Finally, according to the NANPA website, if no local exchange carrier reports access or usage for a given CIC, NANPA is obliged to reclaim it. The semi-annual utilization and access reporting mechanism is described at length in the guidelines.
AUGUST 1: 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. 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.
AUGUST 1: 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 1. 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 transferring the resold service to another carrier is required to report those numbers but the carrier receiving such numbers should not report them. 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.
AUGUST 29: COPYRIGHT STATEMENT OF ACCOUNTS. The Copyright Statement of Accounts form plus royalty payment for the first half of calendar year 2015 is due to be filed August 29 at the Library of Congress’ Copyright Office by cable TV service providers.
SEPTEMBER 1: FCC FORM 477, LOCAL COMPETITION AND BROADBAND REPORTING FORM. Three[sic] types of entities must file this form.
- Facilities-based Providers of Broadband Connections to End User Locations: Entities that are facilities-based providers of broadband connections – which are wired “lines” or wireless “channels” that enable the end user to receive information from and/or send information to the Internet at information transfer rates exceeding 200 kbps in at least one direction – must complete and file the applicable portions of this form for each state in which the entity provides one or more such connections to end user locations. For the purposes of Form 477, an entity is a “facilities-based” provider of broadband connections to end user locations if it owns the portion of the physical facility that terminates at the end user location, if it obtains unbundled network elements (UNEs), special access lines, or other leased facilities that terminate at the end user location and provisions/equips them as broadband, or if it provisions/equips a broadband wireless channel to the end user location over licensed or unlicensed spectrum. Such entities include incumbent and competitive local exchange carriers (LECs), cable system operators, fixed wireless service providers (including “wireless ISPs”), terrestrial and satellite mobile wireless service providers, MMDS providers, electric utilities, municipalities, and other entities. (Such entities do not include equipment suppliers unless the equipment supplier uses the equipment to provision a broadband connection that it offers to the public for sale. Such entities also do not include providers of fixed wireless services ( e.g., “Wi-Fi” and other wireless ethernet, or wireless local area network, applications) that only enable local distribution and sharing of a premises broadband facility.)
- Providers of Wired or Fixed Wireless Local Telephone Services: Incumbent and competitive LECs must complete and file the applicable portions of the form for each state in which they provide local exchange service to one or more end user customers (which may include “dial-up” ISPs).
- Providers of Interconnected Voice over Internet Protocol (VoIP) Service: Interconnected VoIP service is a service that enables real-time, two-way voice communications; requires a broadband connection from the user’s location; requires Internet-protocol compatible customer premises equipment; and permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network. Interconnected VoIP providers must complete and file the applicable portions of the form for each state in which they provide interconnected VoIP service to one or more subscribers, with the state determined for reporting purposes by the location of the subscriber’s broadband connection or the subscriber’s “Registered Location” as of the data-collection date. “Registered Location” is the most recent information obtained by an interconnected VoIP service provider that identifies the physical location of an end user.
- Providers of Mobile Telephony Services: Facilities-based providers of mobile telephony services must complete and file the applicable portions of this form for each state in which they serve one or more mobile telephony subscribers.
- A mobile telephony service is a real-time, two-way switched voice service that is interconnected with the public switched network using an in-network switching facility that enables the provider to reuse frequencies and accomplish seamless handoff of subscriber calls.
- A mobile telephony service provider is considered “facilities-based” if it serves a subscriber using spectrum for which the entity holds a license that it manages, or for which it has obtained the right to use via lease or other arrangement with a Band Manager
SEPTEMBER 30: FCC FORM 396-C, MVPD EEO PROGRAM REPORTING FORM. Each year on September 30, multi-channel video program distributors (“MVPDs”) must file with the Commission an FCC Form 396-C, Multi-Channel Video Programming Distributor EEO Program Annual Report, for employment units with six or more full-time employees. Users must access the FCC’s electronic filing system via the Internet in order to submit the form; it will not be accepted if filed on paper unless accompanied by an appropriate request for waiver of the electronic filing requirement. Certain MVPDs also will be required to complete portions of the Supplemental Investigation Sheet (“SIS”) located at the end of the Form. These MVPDs are specifically identified in a Public Notice each year by the FCC.
Calendar At A Glance
Jul. 16 – Comments are due on Part 4 Outage Reporting NPRM.
Jul. 20 – PRA comments are due on the Open Internet Order.
Jul. 27 – Comments are due on FirstNet Draft RFP.
Jul. 31 – Reply comments are due on Part 4 Outage Reporting NPRM.
Jul. 31 – FCC Form 507 (Universal Service Quarterly Line Count Update) is due.
Jul. 31 – Carrier Identification Code (CIC) Report is due.
Aug. 1 – FCC Form 502 due (North American Numbering Plan Utilization and Forecast Report).
Aug. 1 – FCC Form 499-Q (Quarterly Telecommunications Reporting Worksheet) is due.
Aug. 5 – Comments are due on Transparency Exemption proceeding.
Aug. 13 – Effective date for Lifeline rule revisions (including document retention requirements).
Aug. 21 – Comments due on Video Programming Competition Report.
Aug. 29 – Copyright Statement of Accounts is due.
Sep. 1 – FCC Form 477 due (Local Competition and Broadband Report).
Sep. 4 – Reply comments are due on Transparency Exemption proceeding.
Sep. 21 – Reply comments are due on Video Programming Competition report.
Sep. 25 – Comments are due on Section IV.B of the Special Access Data NPRM.
Sep. 30 – FCC Form 396-C (MVPD EEO Program Annual Report).