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. 17, No. 24 | June 18, 2014 |
Headlines
FCC Staff and Industry Experts Shed Light on Incentive Auction During a public seminar on Monday, FCC staff and industry representatives shed some light on the legal, policy and implementation questions behind the broadcast incentive auction and the 600 MHz band plan. While a significant number of complex rulemakings need to be completed before the auction can begin, and other proceedings still need to be commenced, the Chair of the FCC Incentive Auction Task Force and other FCC staff were optimistic that the Commission could meet its mid-2015 target date for the incentive auction. Representatives for CTIA commended the FCC for its openness and transparency throughout the rulemaking that led to the FCC’s May 15 Incentive Auction Report and Order ( FCC 14-50 ) (Staff Summary) and for coming up with a 600 MHz band plan that maximizes the amount of paired-channel licensed spectrum that would be available for bidding. Rural wireless advocates praised the Commission for soliciting industry input on the compromise that that resulted in Partial Economic Areas (PEAs) being chosen as the basis for 600 MHz band geographic licensing. The 416 PEAs ( PEA Map and Data ) are significantly smaller than the 175 Economic Areas (EAs) initially proposed by the Commission, and should help to free up more 600 MHz spectrum for bidding in rural areas where there tend to be fewer broadcasters. As a result, upwards of 120 megahertz in paired channel spectrum could be made available for bidding in many rural markets. Others in attendance were less optimistic. National Association of Broadcasters executive VP and spectrum auction point person Rick Kaplan made it clear that TV broadcasters who wished to remain on the air were “none too happy” with the Incentive Auction R&O. In recent weeks, broadcasters have voiced concerns about new coverage and interference software that was adopted by the Commission and that is central to the repacking process. The Commission has an obligation under the Spectrum Act of 2012 to use “all reasonable efforts” to preserve the coverage areas and populations served by the remaining TV stations. However, broadcasters have significant questions about the potential for service disruptions and compensation that broadcasters will receive when transitioning to the shrunken TV band. Broadcasters also have concerns about the “catalog of expenses” that will be eligible for reimbursement as part of the post-auction transition. Each station’s transition will be different, and there are questions about the availability of equipment and personnel, as well as environmental and weather concerns. The FCC has yet to clarify what will happen if remaining TV stations are unable to complete their transition to new facilities within the 39 months currently allocated under the Commission’s Rules. Will they be forced off the air, or will the FCC grant reasonable extensions to three-year construction permits? Granting extensions to broadcasters would delay the roll-out of LTE networks in the 600 MHz band. FCC Media Bureau staff clarified that relocation/repacking reimbursement from the $1.75 billion Reimbursement Fund would not only be available for broadcasters that are assigned new channels, but also for costs reasonably incurred by MVPDs (including some of our clients) to continue to carry such stations. The FCC intends to issue eligible stations and MVPDs an initial allocation of funds, in designated individual accounts in the United States Treasury, to cover the majority of their estimated costs. The funds will be available for draw down as expenses are incurred. Additional funds will be allocated as necessary prior to the three-year statutory deadline for all reimbursements. When asked whether NAB would seek reconsideration or a legal challenge of the incentive auction rules, Kaplan said the association and its members were still weighing their options. Any such challenges could delay (perhaps significantly) the incentive auction process. This past spring Kaplan
said he believes the incentive auction could be moved to late 2015 or perhaps 2016. Kaplan also said that a robust AWS-3 spectrum auction later this year would mean less financial pressure on the incentive auction timetable. The amount of 600 MHz spectrum available for bidding in major markets will depend on the number of broadcasters that voluntarily participate in the auction, and the FCC staff said that the Commission would be looking to clear more than just the top 20 markets. In other markets, the Commission should able to free up between 84 and 126 megahertz of contiguous spectrum simply through repacking. Lesser amounts of spectrum may be available in markets bordering Canada and Mexico, due to the need to protect broadcast operations in these countries. FCC staff reported that band allocation negotiations have been underway with these sovereigns since 2011. Canada is expected adopt a 600 MHz band plan that is similar to that used in the US, but this is not a sure thing. Mexico appears to be opting instead for a 600 MHz band plan adopted by the Asia-Pacific Telecommunity (or “APT”), as it did for the 700 MHz band to facilitate greater economies of scale. Bidders for boundary areas will want to stay on top of this situation,so they are aware of how technical rules might impact their operations before bidding. To facilitate broadcaster participation, FCC staff said that opening bids in the reverse auction would be high. A series of reverse auction rounds would be conducted (with lower prices in each successive round) until a clearing target is met, and the Commission would then run its repacking and band optimization software (a process that could take days or weeks) and then turn to a forward auction to determine the prices that potential users of the repurposed spectrum would pay for new flexible-use licenses. The forward auction will be somewhat different from other auctions in that bidding will be for “generic” 5 x 5 megahertz paired blocks that will be translated to specific licenses at the end of the auction (as is typically done in European spectrum auctions). The FCC believes that bidding for generic blocks will help speed up the forward auction, reducing the time and cost of bidder participation. The “final stage rule” will determine when the auction closes and will allow market forces to determine the amount of spectrum cleared and total revenues raised. Among the proceedings still to come from the FCC to set the table for the 600 MHz auction: - Auction Comment Public Notice
- Auction Procedures Public Notice
- Inter-service Interference Public Notice
- Aggregate Interference Report & Order
- Designated Entity (DE) Rules Reform Proceeding
- Part 15/Unlicensed Proceeding
- Wireless Microphones Spectrum Proceeding
- LPTV and Translators Proceeding
We will provide more details and analysis of these proceedings as they are announced. Our law firm’s clients who may be interested in bidding for 600 MHz band spectrum will want to focus their attention especially on the DE Rules Reform and Auction Comment/Procedures items. Comments Filed on Communications Act Update Third White Paper Comments were filed on June 13, 2014, on the House Energy and Commerce Committee’s third white paper on updating the Communications Act. As we reported in a previous edition of the BloostonLaw Telecom Update, this paper addressed competition policy and the role of the FCC, and sought public input on 10 questions geared toward determining how the Communications Act and FCC policies could promote or limit competition in the marketplace. The Alarm Industry Communications Committee filed comments discussing the need for assurances that evolving communications networks will be reliable and stable in the event of emergencies; that spectrum should be available for alarm services; and that alarm data is able to be transmitted reliably regardless of technology. xG Technology, Inc., a cognitive radio technology firm, filed comments discussing the benefits of shared-use spectrum in the growing spectrum crunch environment, and supported a more narrow role for the FCC in which it continued to manage frequencies and spectrum, while leaving regulation of competition issues primarily to the market itself and the Justice Department, as needed. CTIA — the Wireless Association filed white paper comments urging Congress to reduce the role of the FCC in regulating the telecom industry, citing a “vibrant and competitive marketplace” as creating an environment in which only “light touch” regulation by the FCC is necessary. CTIA therefore asks Congress to narrow the FCC’s authority to only those areas where competition may not “produce the desired result”. CTIA asks that most regulation of competition be handled through Antitrust laws, and asks the FCC to spur “intermodal competition” by regulating all competing carriers the same and making more spectrum available. NECA’s Washington Watch is reporting that ITTA argued that Congress should provide the FCC the flexibility to evaluate when regulation is needed and to act when a marketplace failure has been demonstrated to exist; and that the FCC should recognize the differing challenges inherent in serving rural vs. more urban markets. USTelecom said Congress should acknowledge that competition has arrived and that a light regulatory touch is what will bring about the virtuous cycle of investment, new technologies and consumer choice, rather than a continued and failed adherence to 19th century concepts repealed decades ago at the federal level for virtually every other common carrier industry. NECA further reported that TIA said telecommunications policy should replace the current regulatory silos that are based on legacy services, and said a legislative focus on specific, well-defined public interest objectives will ultimately prove more durable in achieving those objectives as technology evolves, rather than an approach that micro-manages how content providers, network operators and customers should relate to each other. BloostonLaw assisted a number of clients in participating in the third white paper comment proceeding before Congress, and will continue to do so as the record is built. Clients interested in participating in the ongoing Communications Act Update Effort should contact the firm without delay. Democrats Introduce Legislation To Ban Internet “Fast Lane” On June 17, Senator Patrick Leahy (D-VT) and Rep. Doris Matsui (D-CA) introduced the Online Competition and Consumer Choice Act, which explicitly directs the FCC to stop ISPs from letting companies pay to get their content to customers faster. Specifically, the bill gives the FCC 90 days from its enactment to promulgate regulations that: (1) prohibit a broadband provider from entering into an agreement with an edge provider under which that broadband provider agrees, for consideration, to give preferential treatment or priority of the edge provider’s traffic and
(2) prohibit a broadband provider from giving preferential treatment or priority to its own traffic or an affiliate’s traffic.
Senator Al Franken (D-Minn.), Congressman Henry Waxman (D-Calif.), and Congresswoman Anna Eshoo (D-Calif.) are original cosponsors of the legislation. “Americans are speaking loud and clear — they want an Internet that is a platform for free expression and innovation, where the best ideas and services can reach consumers based on merit rather than based on a financial relationship with a broadband provider,” said Senator Leahy. “A free and open Internet is essential for consumers, and to encourage innovation and competition in the Internet ecosystem. Our country cannot afford ‘pay-for-play’ schemes that divide our Internet into tiers based on who has the deepest pockets. The Online Competition and Consumer Choice Act will ban paid prioritization and ensure fair competition and consumer choices online,” said Congresswoman Matsui. “Net neutrality is the principle that all Internet traffic must be treated equally,” said Senator Franken, who chairs the Senate Judiciary Subcommittee on Privacy, Technology and the Law. “And that’s the way it should be—the website of a Minnesota small business should load as quickly as the website of a large business.” FCC Proposes Comprehensive Regulatory Fee Reforms As part of its annual adjustments to the regulatory fee collection program, the FCC has released a Notice of Proposed Rulemaking in which it has proposed significant adjustments to the program itself — as well as to the fee schedule. The reforms are designed to make the regulatory fees more equitable across the FCC’s users as well as more transparent. Comments are due Monday, July 7, 2014 and Reply Comments are due the following Monday on July 14, 2014. Below is a list of the FCC’s proposed annual fee adjustments for this year: | Category | FY2013 | FY2014 | | CMRS Mobile/Cellular (Parts 20, 22, 24, 27, 80 & 90) | $0.18 | $0.18 | CMRS Messaging (Paging and IMTS – Parts 20, 22,
24 and 90) | $0.08 | $0.08 | | Broadband Radio Service | $510.00 | $720.00 | | Local Multipoint Distribution Service | $510.00 | $720.00 | | CARS | $510.00 | $605.00 | | CATV/IPTV | $1.02 | $1.00 | | Satellite Earth Stations | $245.00 | $275.00 | Interstate Telecommunications Service Providers
(Per Revenue Dollar) | $0.00347 | $0.00340 | | Part 90 Private Land Mobile (Exclusive Use) | $40.00 | $35.00 | | Part 90 Private Land Mobile (Shared Use) | $15.00 | $10.00 | | Part 101 Microwave | $20.00 | $15.00 | | 218-219 MHz (formerly IVDS) | $75.00 | $85.00 | | Marine Ship | $10.00 | $15.00 | | Marine Coast | $55.00 | $55.00 | | Aviation (Aircraft) | $10.00 | $10.00 | | Aviation (Ground) | $15.00 | $35.00 |
In addition to the annual fee adjustments described above, the FCC is proposing the following long term reforms which will be of interest to our clients: CMRS Messaging (Part 22 and 90 Paging and IMTS) Like last year, the FCC has proposed to retain the $0.08 per subscriber unit regulatory fee for the paging/IMTS services in recognition of the poor financial condition of the industry. Because the FCC collects a relatively small amount from CMRS Messaging providers, as discussed below it has proposed to eliminate this fee category so that, if adopted, fees from paging and IMTS service providers would no longer be collected. De minimis Threshold Exemption and Elimination of Regulatory Fee Categories Under the Commission’s present policy, a regulatee is exempt from the payment of regulatory fees if the sum total of all its regulatory fees for the year is less than $10.00. To put the current exemption in perspective, the FCC has indicated that Interstate Telephone Service Provider (ITSP) would be exempt if its annual gross revenues did not exceed $2,881 while a CMRS wireless carrier would be exempt if it had fewer than 55 subscribers. Likewise, a CATV or ITSP operator would be exempt if it had fewer than 9 customers. The FCC is proposing to increase the de minimis threshold in order to provide relief to more of the smaller entities, and is seeking comment on (a) whether to increase the exemption threshold amount to $100.00, $500.00, $750.00 or $1,000.00; (b) whether such change should be implemented this fiscal year or implemented over a period of years and (c) whether the administrative burden on smaller entities and the FCC’s operational costs associated with the processing and collection of these small fees outweighs the benefits of the small payments. Finally, the FCC has also asked whether certain categories of licensees that are subject to frequency coordination by private industry groups ( e.g., Microwave, Part 90 Private Land Mobile, etc.) should be excluded from the regulatory fee program due to limited Commission regulation. These proposals, if adopted, have the potential to benefit many of our paging and Private User clients. Satellite Earth Stations Several of our clients hold satellite transmit/receive earth station licenses. The FCC has noted that while transmit receive earth stations are interrelated to space stations that have regulatory fees that are $140,000 to $150,000 per station, the fee for the earth station is significantly less at $275.00 per license. In this regard, the FCC notes that earth station and satellite station oversight and regulation is interdependent and involves issues that relate to non-US licensed space stations as well. Commenters in prior proceedings have urged the FCC to increase the percentage of the regulatory fee allocated to the earth stations. As a result, the FCC is now seeking comment on whether to increase the allocation of the regulatory burden from the space stations to the earth stations to more accurately reflect the regulatory burden associated with the earth stations. Additionally, the FCC is also asking whether the type of earth station authorization should affect the relative allocation for regulatory fees. Combining ITSP and Cellular Fee Categories The FCC is proposing to consolidate the Interstate Telephone Service Provider and the wireless CMRS cellular services categories into a single regulatory fee category. The basis for this proposal is that the services provided by ITSPs and wireless providers are “comparable” and subject to similar regulations ( e.g., Universal Service, CPNI, number portability, etc.). When initially proposed last year, the Independent Telephone and Telecommunications Alliance (ITTA) stated that wireline companies bear a disproportionately high proportion of regulatory fees because the FCC is no longer providing the same level of regulatory oversight as it had when the fees were first adopted; and that regulations that affect wireline voice carriers also apply to VoIP and wireless providers of voice telephone service. In order to level the playing field between wireline voice and wireless voice providers, the FCC is seeking to calculate the regulatory fee for wireline and wireless voice providers based upon the number of full-time equivalents (FTEs) in the FCC’s Wireline Competition Bureau and the Wireless Telecommunications Bureau. In this regard, the FCC has asked whether any other services should be included in this category. The FCC notes that the current fee methodology for wireline carriers is very different from the wireless carriers since the wireless fee is based upon the number of handsets while the wireline fee is calculated based upon revenue dollars. Because of the different calculation methods, the FCC is looking to create a uniform calculation method — whether it be based upon revenues, handsets, phone numbers, etc. The FCC has indicated that a revenue based fee would be feasible since it already collects the data on the Form 499 that is used to calculate obligations for other programs such as Universal Service. Nonetheless, the FCC is also concerned that a combination of these fee categories into a single category could result in a significant increase in regulatory fees for wireless providers, especially if it adopts a revenue based fee. As a result, the FCC is also asking for comment on whether there should be a transition period, and whether there should also be a cap on any fee increase — which the FCC has suggested could be 7.5% or 10% annually. The FCC is also seeking comment on the best way to transition the two service categories into a single category in order to minimize the revenue impact on other regulated services. CATV Services Last year, the FCC concluded that Internet Protocol Television (IPTV) services should be included in the CATV regulatory classification even though the IPTV service is not a CATV service. This year, the FCC is now considering whether to add Direct Broadcast Satellite (DBS) Operators to this regulatory category and to rename it using a more descriptive identifier such as “MVPD” or “subscription television fees” or some other name that would be appropriate. The FCC notes that by including DBS Operators in this fee category, the regulatory fee paid by CATV and IPTV operators would drop from $1.00 per subscriber (proposed for FY2014) to $0.68 per subscriber. The FCC is also seeking comment on the relationship between regulatory fees that would be paid by DBS satellite television service providers and the regulatory fees paid by operators of GSO satellites — which are also used to provide satellite television service to consumers in the United States. In this regard, the FCC has also asked about non-US satellites that are used to provide television programming in the US (presumably, the implication being whether or not there is a way to assess fees against those satellite operators). Wireline Competition Bureau Presents Status on IP Transition, AT&T Trials The Wireline Competition Bureau (WCB) reported on the AT&T IP transition trials at the Commission's June 13, 2014, Open Meeting. In addition to summarizing AT&T's proposal to conduct IP trials in wire centers in Florida and Alabama, the WCB reported that issues had been raised about the trials including: AT&T's proposed fixed wireless service would be higher priced with lower data allowance compared to AT&T’s DSL (digital subscriber line) service; the inability to offer GETS (Government Emergency Telephone Service) over interconnected VoIP (voice-over-IP) service; concerns about the availability of fiber service during power outages; and the lack of a wholesale option. Also at the meeting, it was announced that the FCC plans to seek bids for parties interested in developing a methodology for data collection and analysis during tech trials, as well as providing input during the collection and analysis. Law & Regulation FCC Declines to Mandate “Spectrum Etiquette” in Unlicensed Bands The FCC has terminated a proceeding, begun in 2003 (ET Docket No. 03-201), that looked toward, among other things, establishing a “spectrum etiquette” in the unlicensed 900 MHz band and possibly other unlicensed bands, in order to improve sharing of this spectrum among the multitude of users. No specifics were proposed at the time. In 2004, the FCC addressed other aspects of its earlier proposal but declined to adopt a spectrum etiquette, based on considerable opposition. Cellnet Technologies, a company engaged in meter reading, petitioned the FCC for reconsideration. Although, in 2007, the FCC dismissed the petition as lacking in specifics, it nevertheless proposed a spectrum etiquette for the 902-928 MHz band with features that included listening-before-talking and a transmission duty cycle. The FCC also asked whether, assuming a limited duty cycle, synchronization among multiple devices should be allowed and whether the spectrum etiquette should be applied only to digitally modulated devices or possibly others as well; and whether the spectrum etiquette should also be instituted in the unlicensed 2.4 and 5.8 GHz bands. Citing wide disagreement among commenting parties, the FCC, in an order released June 10, dismissed the spectrum etiquette proposal, stating that it failed to see the need for it. The FCC also observed that since 2007, the Commission has approved more than 2,500 unlicensed devices operating in the 902-928 MHz band, thereby indicating that the band continues to be heavily used under the existing rules for unlicensed operation. The Commission also appeared concerned that adoption of spectrum etiquette would impede design flexibility and innovation of a wide variety of devices that the current rules enable. House Subcommittee to Hold Hearing on Net Neutrality On June 20, 2014, the House Judiciary Committee’s Subcommittee on Regulatory Reform, Commercial and Antitrust Law will hold a hearing entitled Net Neutrality: Is Antitrust Law More Effective than Regulation in Protecting Consumers and Innovation? The witness panel for the hearing includes: Joshua D. Wright, Federal Trade Commission Commissioner; Robert McDowell, Former FCC Commissioner and Visiting Fellow at Hudson Institute, Inc.; Bruce M. Owen, Morris M. Doyle Centennial Professor in Public Policy and Director of the Public Policy Program in the School of Humanities and Sciences at Stanford University; and Tim Wu, professor of law at Columbia Law School. The hearing will be held at 9:00 a.m., and will be broadcast live here . Commission Announces Third Quarter USF Contribution Factor The FCC’s Office of Managing Director released a Public Notice on June 12, 2014, announcing a proposed USF contribution factor for Third Quarter 2014 of 15.7 percent. This is down from 16.6 percent in the previous quarter. According to the Public Notice, contributions to the federal universal service support mechanisms are determined using a quarterly contribution factor calculated by the FCC, based on the ratio of total projected quarterly costs of the universal service support mechanisms to contributors’ total projected collected end-user interstate and international telecommunications revenues, net of projected contributions. If the FCC takes no action regarding the projections of demand and administrative expenses and the proposed contribution factor within 14 days following release of the Public Notice, they are deemed approved and the contribution factor will be used by USAC to calculate third quarter 2014 universal service contributions. FCC Extends Separations Freeze Another Three Years On June 13, the FCC issued a Report and Order extending the existing freeze of Part 36 category relationships and jurisdictional cost allocation factors another three years, through June 30, 2017. The freeze originally began on July 1, 2001, and was scheduled at that time to last for a period of five years. It was intended to provide stability and regulatory certainty for incumbent LECs by minimizing any impacts on separations results that might occur due to circumstances not contemplated by the FCC’s Part 36 rules, such as growth in local competition and new technologies. In 2006, the FCC extended the freeze for three years or until comprehensive reform could be completed, whichever came first. The freeze was subsequently extended by one year in 2009, 2010, and 2011 and by two years in 2012. In 2011, the FCC adopted the USF/ICC Reform Order, which comprehensively reformed the universal service and intercarrier compensation systems and proposed additional reforms. Since, at this time, the Joint Board on Separations is still considering the impact of those reforms, the FCC sought comment on extending the freeze for another three years, and ultimately adopted it on the grounds that extension of the freeze is necessary to avoid regulatory instability and substantial administrative burdens on carriers. Commissioner O’Rielly issued a statement questioning the need to continue the jurisdictional separations rules in light of intervening regulatory and marketplace changes, and said he hopes the Federal-State Joint Board on Jurisdictional Separations will use this additional three-year window to complete a comprehensive review, with an eye toward ending these rules. Inmate Calling Services Data Collection Effective June 12; Due Date Forthcoming On June 12, Notice appeared in the Federal Register announcing that the information collection requirement in Section III.I of the FCC’s 2013 Inmate Calling Order was approved by OMB on June 2, 2014, and is effective June 12. In the Order, the FCC required all ICS providers to provide data to document their costs for interstate, intrastate toll and local ICS for the past year. It is important to note that although the effective date has been established, a due date for the data required under the collection has not. The FCC said it will be announced in a separate notice at a later date. Industry
Chairman Wheeler Issues Statement on Internet Congestion On June 13, 2014, FCC Chairman Tom Wheeler issued a statement stating his concerns regarding consumer complaints revolving around the exchange of traffic between ISPs and other networks and services; and stating that he has directed the FCC’s staff to acquire the information necessary to determine precisely what is transpiring in the industry. His basic theme was that consumers should get what they pay for. According to the Chairman, “[f]or some time now we have been talking about protecting Internet consumers. At the heart of this is whether [ISPs] that provide connectivity in the final mile to the home can advantage or disadvantage content providers, and therefore advantage or disadvantage consumers. What we call the Open Internet rule on which we are currently seeking comment is one component of this. If adopted, the new rule would prohibit bad acts such as blocking content or degrading access to content. This kind of activity within an ISP’s network has traditionally been the focus of net neutrality. But there is another area of Internet access, and that is the exchange of traffic between ISPs and other networks and services. The recent disputes between Netflix and ISPs such as Comcast and Verizon have highlighted this issue”. With respect to the cause, he stated that the FCC doesn’t “know the answers and we are not suggesting that any company is at fault.” The Chairman also stated that the basic issue surrounding these consumer complaints is “what is going on and what can the FCC do on behalf of consumers? Consumers pay their ISP and they pay content providers like Hulu, Netflix or Amazon. Then when they don’t get good service they wonder what is going on. I have experienced these problems myself and know how exasperating it can be. . . Consumers must get what they pay for. As the consumer’s representative [the FCC needs] to know what is going on.” The Chairman further stated that he has “directed the Commission staff to obtain the information we need to understand precisely what is happening in order to understand whether consumers are being harmed. Recently, at my direction, Commission staff has begun requesting information from ISPs and content providers. We have received the agreements between Comcast and Netflix and Verizon and Netflix. We are currently in the process of asking for others.” The Chairman emphasized that “what we are doing right now is collecting information, not regulating.” He concluded by saying that “[t]he bottom line is that consumers need to understand what is occurring when the Internet service they’ve paid for does not adequately deliver the content they desire, especially content they’ve also paid for. In this instance, it is about what happens where the ISP connects to the Internet. It’s important that we know — and that consumers know.” Calendar At-A-Glance
June
Jun. 16 – ILEC Tariff filings made on 15 days’ notice are due.
Jun. 16 – Connect America Fund ICC Data Filing (Access Recovery Charge changes) is due for tariff filings made on 15 days’ notice.
Jun. 18 – Retransmission consent rules become effective.
Jun. 23 – Petitions to suspend or reject tariff filings made on 15 days’ notice are due.
Jun. 24 – ILEC tariff filings made on 7 days’ notice are due.
Jun. 24 – Connect America Fund ICC Data Filing (Access Recovery Charge changes) is due for tariff filings made on 7 days’ notice.
Jun. 26 – Replies to petitions to suspend or reject tariff filings made on 15 days’ notice are due.
Jun. 26 – Petitions to suspend or reject tariff filings made on 7 days’ notice are due.
Jun. 27 – Replies to petitions to suspend or reject tariff filings made on 7 days’ notice are due. July
Jul. 1 – FCC Form 481 (Carrier Annual Reporting Data Collection Form) is due.
Jul. 1 – FCC Form 690 (Mobility Fund Phase I Auction Winner Annual Report) is due.
Jul. 3 – FCC Application Filing Fees increase.
Jul. 7 – Comments are due on proposed FCC fee revisions.
Jul. 10 – Comments are due on T-Mobile Data Roaming Petition.
Jul. 14 – Comments are due on Citizens Broadband Radio Service FNPRM.
Jul. 14 – Reply comments are due on proposed FCC fee revisions.
Jul. 15 – Comments are due on the Open Internet NPRM.
Jul. 15 – Comments are due refreshing the record on the 2010 Broadband NOI.
Jul. 31 – FCC Form 507 (Universal Service Quarterly Line Count Update) is due.
Jul. 31 – Carrier Identification Code (CIC) Report is due. August
Aug. 1 – Reply comments are due on Citizens Broadband Radio Service FNPRM.
Aug. 11 – Reply comments are due on T-Mobile Data Roaming Petition. September
Sep. 10 – Reply comments are due on the Open Internet NPRM.
Sep. 10 – Reply comments are due refreshing the record on the 2010 Broadband NOI. | 
David George and Bill Noyes
