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. 22 | May 27, 2015 |
FCC Form 481 Due July 1 The FCC’s Form 481 is due annually on July 1 of each year, and requires eligible telecommunications carriers to report, among other things, outage, unfulfilled service request, and complaint data, broken out separately for voice and broadband services, information on the ETC’s holding company, operating companies, ETC affiliates and any branding in response to section 54.313(a)(8); its CAF-ICC certification, if applicable; its financial information, if a privately held rate-of-return carrier; and its satellite backhaul certification, if applicable. BloostonLaw has experience handling Form 481 and is available to assist with this year’s filing. Headlines
FCC Releases Robocall Consumer Protection Fact Sheet As this edition of the BloostonLaw Telecom Update went to press, the FCC released a fact sheet providing information on a proposed declaratory ruling currently being circulated by FCC Chairman Tom Wheeler, aimed at protecting consumers from unwanted robocalls, spam text messages, and telemarketing calls. The proposal will be voted on at the FCC’s June Open Meeting. The ruling comes as a response to two dozen petitions that sought clarity on how the Commission enforces the Telephone Consumer Protection Act (TCPA). According to the press release, the Chairman’s set of actions will, if adopted, “close loopholes and strengthen consumer protections already on the books.” Proposed rulings would: - Give consumers the right to revoke their consent to receive robocalls and robotexts in any reasonable way at any time;
- Permit carriers to offer robocall-blocking technologies to consumers;
- Prohibit callers from calling numbers that have been reassigned to new consumers;
- Create a clear definition of “autodialer” to ensure robocallers cannot skirt consumer consent requirements through changes in calling technology design or by calling from a list of numbers;
- Allow very limited and specific exceptions for urgent circumstances, such as free calls or texts to alert consumers to possible fraud on their bank accounts or remind them of important medication refills (and consumers would have the ability to opt out of even these sort of notifications);
Since the proposal is a declaratory ruling and therefore not considered a prospective rule making, it will be considered effective immediately upon a successful vote. PSHSB Announces User Testing for 911 Reliability Certification System Yesterday, the Public Safety and Homeland Security Bureau (Bureau) announced that an initial version of the FCC’s online system for filing 911 reliability certifications is now available for user testing. As we reported in November of last year, an Initial Reliability Certification of substantial progress toward meeting the requirements of the full Annual Reliability Certification will be due October 15, 2015. The requirements, originally adopted at the end of 2013, require "Covered 911 Service Providers" to meet an annual certification requirement and to take "reasonable measures" to ensure 911 circuit diversity, availability of backup power at central offices that directly serve PSAPs, and diversity of network monitoring links. Under the rules, substantial progress is defined as compliance with standards of the full certification in at least 50 percent of the Covered 911 Service Provider’s critical 911 circuits, central offices that directly serve public safety answering points (PSAPs), and independently monitored 911 service areas. The Bureau intends the testing period to allow Covered 911 Service Providers to familiarize themselves with the certification system through the separate test mechanism and to provide feedback on its content, its usability, and its clarity in advance of their actual certification filings. Information submitted during the testing period will not count toward Initial Reliability Certifications or bind certifying entities to particular responses and will be deleted when the actual production system opens for submissions. Because user identities in the test system are not transferred to the production system, users will have to create a new user identity on the production system. We will be glad to help clients navigate the test process. The test system is available at https://apps2demo.fcc.gov/rcs911/Login.cfm . Waiver of Access Rules Sought In Connection with Study Area Merger Butler-Bremer Mutual Telephone Company, Inc. (Butler-Bremer) has filed a petition for waiver of certain FCC rules concerning interstate access revenue requirement and base period revenue, in connection with its intention to merge its two study areas. Butler-Bremer requests waiver of section 51.909(a) to recalculate rate bands and charges for local switching, tandem switching, and dedicated transport services, and sections 51.917(b)(1), and 51.917(b)(7) of the rules to recalculate the 2011 Interstate Switched Access Revenue Requirement and 2011 Rate-of-Return Base Period Revenue necessary to determine Connect America Fund- Intercarrier Compensation support. Although Butler-Bremer believes it is not required to seek a study area waiver because it is a holding company that is consolidating existing study areas in the same state, it states that the waivers are necessary because its study areas currently are in different Rate Bands for Local Switching and Dedicated Transport Services and the waivers will allow it to establish consolidated rate bands and access rates for its merged study areas. The waiver also will allow it to combine the 2011 Rate-of-Return Carrier Base Period Revenue for the two study areas into a single 2011 Rate-of-Return Carrier Bases Period Revenue amount for the merged study area. Butler-Bremer states that the waiver is in the public interest because merger of the study areas is consistent with the FCC’s policy; the consolidation of the access rate bands is revenue neutral; and the combined Base Period Revenue produces no adverse impact on the Connect America Fund Intercarrier Compensation mechanism. Comments on the petition (assigned WC Docket No. 15-118) are due by June 10, 2015, and reply comments are due by June 22, 2015. Comment Sought on List of Services Eligible for Schools and Libraries Support The Wireline Competition Bureau (WCB) seeks comment on the proposed eligible services list (ESL) for Category One and Category Two services eligible for the schools and libraries universal support mechanism for funding year 2016. (WC Docket No. 13-184) Eligible schools and libraries may seek E-rate support for eligible Category One telecommunications services, telecommunications, and Internet access and Category Two internal connections, basic maintenance, and managed internal broadband services. The list of proposed eligible services can be found here . Comments are due by June 22, 2015 and reply comments are due by July 6, 2015. The list reflects the FCC’s ruling in the Second E-rate Modernization Order, in which the FCC expanded the options available for purchasing affordable high-speed connectivity to include dark fiber and to allow applicants to self-provision high-speed broadband networks “if the applicant is able to demonstrate that self-provisioning is the most cost-effective option and is able to satisfy certain other conditions.” The proposed ESL includes explanatory notes regarding leased lit and dark fiber and self-provisioned broadband networks. According to the FCC, “[t]he notes explain that applicants must seek competitive bids for network maintenance and operation, and all other eligible services and equipment, in order to receive E-rate support.” The proposed ESL also adds a description of eligible special construction or installation charges for Category One services. The WCB also seeks comment on its cost allocation requirements for circuits that carry both voice and data services. According to the FCC, “[t]he full cost of circuits dedicated solely to voice service, including PRIs, SIP trunks, and VoIP provider circuits are subject to the voice services phase down, while the costs for bundled voice and data services provided over a single circuit, must be cost allocated.” The proposed ESL adds ISDN to the list of eligible voice services. However, ISDN also remains listed as an eligible digital transmission service for applicants that may be receiving ISDN as bundled voice and data service, “so that a cost allocation can be sought for the data portion of the service that is not subject to the voice phase down.” Commissioner Rosenworcel to be Renominated as FCC Commissioner On May 20, President Obama announced his intention to renominate Commissioner Jessica Rosenworcel as FCC Commissioner. Rosenworcel, whose current term expires this summer, originally became a Commissioner in 2012, succeeding Michael Copps (for whom she served as Senior Legal Advisor).
Of the renomination, Rosenworcel said: “I am honored that the President has indicated his intent to nominate me for a new term as Commissioner at the Federal Communications Commission. During my tenure at the agency it has been a tremendous privilege to work with my colleagues, the talented staff of the Commission, and the American people to develop policies that expand access to modern communications and the opportunities of the digital age. I look forward to the United States Senate considering my nomination and the continuing opportunity to serve.” Law & Regulation
Latest NANC Recommendations on LNP Go Into Effect on June 25 The Wireline Competition Bureau’s Order of June 20, 2014, in which it adopted recommendations made by the North American Numbering Council (NANC) to change certain local number portability (LNP) “provisioning flows,” was published in the Federal Register yesterday, establishing an effective date of June 25. Specifically, the Bureau adopted changes to existing processes for cancelling a number port request, to the timeline for re-using disconnected ported numbers, and for changing the due date for a port. The Bureau declined to adopt a recommendation concerning a preference for area code overlays instead of area code splits, and left to the states the option to choose the best means of implementing area code relief for their citizens. With respect to the provisioning flows for port cancellations, termed by the NANC as the “Cancel Flows,” the Bureau adopted revisions clarifying that if the customer contacts the current provider, that provider may choose to advise the customer to call the new provider to cancel the port request. If the customer contacts the new provider, that provider must cancel the port. If the current provider decides to cancel the port request, it must obtain verifiable authority from the customer, such as a Letter of Authorization, dated after the initial port request. The new provider must then process the cancellation request, even if the current provider does not provide an actual copy of the authorization. The Bureau also adopted changes to the steps to be taken to notify the new provider of the cancellation, depending on whether the current provider is a wireline or a wireless provider. With respect to the timeline for re-using disconnected ported numbers, the Bureau adopted a recommendation to delete language in section 52.15(f)(ii) of the Commission’s rules that states “[t]he maximum interval between disconnect date and effective release is 18 months,” because it is inconsistent with the Commission’s rules, which provides that a service provider may not “age” disconnected residential numbers for more than 90 days and disconnected business numbers for more than 365 days. The Bureau also adopted the recommendation to accept Best Practice 65, which provides that both service providers involved in a port must agree to any changes to the original due date for that port. This change is intended to close a perceived loophole in the current flows that prompts some new service providers to activate ports before the agreed-to porting date and before the old service providers have their networks ready to port a number out. FCC Releases Regulatory Fee Notice of Proposed Rule Making The FCC has issued its annual Notice of Proposed Rulemaking and Order in connection with the collection of annual regulatory fees for Fiscal Year 2015. Comments on the FCC’s proposals will be due June 22, 2015 and Reply Comments will be due July 6, 2015. This year, the FCC has proposed to collect $339,844,000 in regulatory fees. Of this amount, the FCC will collect $69.3 million or 20.4 percent from Wireless Telecommunications Bureau regulatees, $131.1 million or 38.6 percent from Wireline Competition Bureau regulatees, $21.3 million or 6.28 percent from International Bureau regulatees, and $118.1 million or 34.8 percent from Media Bureau regulatees. DeMinimis Exemption
New this year, the FCC has increased the threshold for the de minimis from $10.00 for all fees owed by a regulate to $500.00. Because this exemption can be changed from time-to-time, it is important that regulates review their regulatory fee obligation annually in order to determine if the fee due for that year will exceed the threshold. We also recommend that those clients claiming an exemption under the de minimis rule affirmatively file a letter with the Commission in order to avoid being red-lighted for non-payment of the regulatory fee. Toll Free Numbers
The FCC has proposed changes to its fee schedule in order to include a regulatory fee subcategory for toll free numbers (subcategory of Interstate Telecommunications Service Providers (ITSP)). For this category, the FCC has proposed setting the fee at $.12 per year (or $.01 per month) for each number that is managed by a Responsible Organization (RespOrg). In order to offset this fee, the FCC is also proposing to reduce the ITSP rate from 0.00340 to 0.00329. While it is important to note that these RespOrgs are not common carriers, the FCC will hold them liable for payment of this new regulatory fee. The FCC has cautioned that RespOrgs that do not pay the required fee will be subject to penalties and enforcement action. In order to ensure that the RespOrgs are aware of this new fee requirement, the FCC is requiring SMS/800, Inc. (the entity that provides administration and routing for all toll free numbers in North America) to provide necessary outreach to the RespOrgs to advise them of the FCC’s new regulatory fee requirement in connection with the provision of 800 toll free numbers. Direct Broadcast Satellite (DBS)
The FCC is proposing to modify the regulatory fee paid by DBS service providers. Essentially, DPS service providers wear two hats – multichannel video programming distributors (MVPDs) and users of geostationary space stations that are used to provide one-way subscription video service to consumers. As a result, DBS providers utilize the services of both the International Bureau and the Media Bureau. In order to properly allocate costs, the FCC is proposing to subject DBS providers to two regulatory fees. The first fee would recover the burden of regulation and oversight by the International Bureau while the second fee would cover the burden of regulation and oversight by the Media Bureau. In order to accomplish this, the FCC will also have to modify its Media Bureau rate structure for MVPDs to have one rate structure for DBS and a separate rate structure for CATV and IPTV. Payment of Regulatory Fees via Credit Card
Effective June 1, 2015, the US Treasury has adopted new rules concerning credit card payments. Under these new rules, the maximum amount that can be charged on a credit card for a particular debt is $24,999.99 (which is reduced from $49,999.99). As a result of this change, charges of more than $24,999.99 will be rejected. It is important to note that this limit applies to both single payments and bundled payments of more than one invoice. Additionally, multiple transactions to a single agency in one day will be added together and treated as a single transaction for purposes of this rule. US Treasury has also indicated that debtors may not split payments into more than one payment by using the same or multiple credit card accounts or by spreading the payments over multiple days. Clients wishing to make payments that exceed $24,999.99 have several options, such as: Visa or MasterCard debit cards, Automated Clearing House (ACH) debits from a bank account, and wire transfers. FCC Expands Accessibility Requirements for Emergency Information in TV Programming On May 21, the FCC adopted new rules requiring that emergency information be made accessible on a secondary audio stream on tablets, smartphones, laptops, and similar devices when subscription television providers, such as cable and satellite operators, and to permit consumers to access programming over their networks using an app on these devices. Specifically, when emergency information appears on a television screen, it is preceded by three tones. Under previously adopted Commission rules, individuals who are blind or visually impaired soon will be able to switch to a secondary audio stream to hear televised emergency information when they hear the three tones; the FCC’s action takes this a step further by requiring the secondary audio stream to also be available on tablets, smartphones, laptops, and the like. Additionally, this item establishes rules requiring that the equipment used to receive and play back television programming, such as set-top boxes, have a “simple and easy” to use mechanism to switch from the main program audio to the secondary audio stream to hear audible emergency information. Also adopted as part of the item was a Second Further Notice of Proposed Rulemaking that asks for comments on additional issues related to the accessibility of emergency information for individuals who are blind or visually impaired, including: - How to prioritize emergency information if there is more than one on-screen announcement;
- Whether information on school closings and school bus schedule changes should continue to be made available on the secondary audio stream; and
- Possible future requirements on multichannel video programming distributors to ensure that consumers have a simple and easy to use mechanism to access the secondary audio stream.
The full text of the Order and Second Further Notice of Proposed Rulemaking is not available at this time. Industry
Charter to Buy Time Warner for $55 Billion
Yesterday, multiple news outlets reported that Charter Communications, Inc. announced that it would buy Time Warner Cable Inc. in a cash-and-stock deal that values the company at $78.7 billion. Charter will pay $195.71 a share, with options of $100 and $115 in cash and the remainder in its own stock, according to a statement Tuesday. Bloomberg reports that Bright House Networks, a smaller cable company that Charter had previously agreed to buy, will also be merged into the combined entity. The combined business will have about 17 million basic cable customers, second to Comcast’s 22 million.
Readers will recall that this is Charter’s second attempt at purchasing Time Warner, with their first bid back in January of 2014 (of $132.50-a-share) being rejected as a “low-ball” offer. According to Bloomberg, Charter Chief Executive Officer Tom Rutledge, who will head the combined company, said on a conference call that he is confident the deal would get approved. In his own statement, FCC Chairman Tom Wheeler said: “The FCC reviews every merger on its merits and determines whether it would be in the public interest. In applying the public interest test, an absence of harm is not sufficient. The Commission will look to see how American consumers would benefit if the deal were to be approved.” Driving and Mobile Devices — a Recipe for Disaster? This past weekend, an article on MotorTrend.com concerning the use of mobile devices while driving began: “It appears as though all the “don’t text and drive” campaigns may need some changes in the near future, because a study released by AT&T reveals drivers who use their phones while driving aren’t just texting. Some are taking selfies and checking into social media, while others are even engaging in video chats.” The use of cell phones has been main stream since the mid-1990s as the devices became smaller and easier to use. Fortunately or unfortunately, over the past 10 years or so, the devices have become smarter — essentially becoming mini-computers that can keep you connected almost as well as an Internet connected desk-top computer. As a result, everyone has become much more dependent on and comfortable with mobile devices, such that these devices have become an extension of the individual user in all facets of life. While access to instant information and the ability to send messages at any time have their benefits, there are also social costs and unintended consequences. As MotorTrend has indicated, of the 2,067 people polled between the ages of 16 and 65 in the US who use their cell phones at least once per day, 70 percent use their smart phones while driving, 61 percent admitted to texting and 33 percent to either reading, sending or replying to e-mails. MotorTrend stated that the poll also indicated that 28 percent surfed the Internet while driving, while 27 percent used Facebook and 14 percent used both Twitter and Instagram. One can conjecture that the use of smart phones has become an addiction for many – whether it be while driving a car or going out on a date with your significant other or spouse. Next time you pull up to a traffic light – look around you. Next time you are at a restaurant, look at the surrounding tables and see how many smart phones are out and in use. You might be surprised. What is the solution? Some states now have laws banning the use of hand-held devices. That certainly is a start, but several years into the existence of such laws a lot of texting and surfing still goes on behind the wheel. But what about use of hands-free Bluetooth? And, what about self-control? Neither seems to be winning the day. Perhaps wireless carriers can help manage the problem through the use of high profile publicity campaigns against distracted driving, and encouraging the use of voice recognition technologies that allow the user to keep their eyes on the road. Significant strides are being made toward apps that allow you to listen to voicemails, texts and e-mails audibly. Deadlines
JUNE 1: FCC FORM 395, EMPLOYMENT REPORT. Common carriers, including wireless carriers, with 16 or more full-time employees must file their annual Common Carrier Employment Reports (FCC Form 395) by May 31. However, because May 31 falls on a Sunday this year, the filing will be due on June 1. This report tracks carrier compliance with rules requiring recruitment of minority employees. Further, the FCC requires all common carriers to report any employment discrimination complaints they received during the past year. That information is also due on June 1. The FCC encourages carriers to complete the discrimination report requirement by filling out Section V of Form 395, rather than submitting a separate report. JULY 1: FCC FORM 481 (CARRIER ANNUAL REPORTING DATA COLLECTION FORM). All eligible telecommunications carriers (ETCs) must report the information required by Section 54.313, which includes outage, unfulfilled service request, and complaint data, broken out separately for voice and broadband services, information on the ETC’s holding company, operating companies, ETC affiliates and any branding in response to section 54.313(a)(8); its CAF-ICC certification, if applicable; its financial information, if a privately held rate-of-return carrier; and its satellite backhaul certification, if applicable. Form 481 must not only be filed with USAC, but also with the FCC and the relevant state commission and tribal authority, as appropriate. Although USAC treats the filing as confidential, filers must seek confidential treatment separately with the FCC and the relevant state commission and tribal authority if confidential treatment is desired. JULY 1: MOBILITY FUND PHASE I ANNUAL REPORT. Winning bidders in Auction 901 that are authorized to receive Mobility Fund Phase I support are required to submit to the Commission an annual report each year on July 1 for the five years following authorization. Each annual report must be submitted to the Office of the Secretary of the Commission, clearly referencing WT Docket No. 10-208; the Universal Service Administrator; and the relevant state commissions, relevant authority in a U.S. Territory, or Tribal governments, as appropriate. The information and certifications required to be included in the annual report are described in Section 54.1009 of the Commission’s rules. 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 2014 is due to be filed August 29 at the Library of Congress’ Copyright Office by cable TV service providers. Calendar At A Glance
May
May 27 – Questions on terms in the FirstNet RFP are due.
May 29 – Comments on Short Form Tariff Review Plans are due. June
Jun. 1 – FCC Form 395 (Annual Employment Report) is due.
Jun. 5 – Reply comments on Short Form Tariff Review Plans are due.
Jun. 5 – Comments are due on the 9-1-1 Non-Service Initialized Device NPRM
Jun. 10 – Comments are due by 5 p.m. Eastern on the Broadband Opportunity Council Notice and Request.
Jun. 16 – Tariffs filed on 15 days’ notice are due.
Jun. 22 – Comments are due on Eligible Services List for E-Rate 2016.
Jun. 23 – Petitions to Suspend or Reject Tariffs filed on 15 days’ notice are due.
Jun. 24 – Tariffs filed on 7 days’ notice are due.
Jun. 26 – Replies to Petitions to Suspend or Reject Tariffs filed on 15 days’ notice are due.
Jun. 26 – Petitions to Suspend or Reject Tariffs filed on 7 days’ notice are due by noon Eastern Time.
Jun. 29 – Replies to Petitions to Suspend or Reject Tariffs filed on 7 days’ notice due by noon Eastern Time. 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. 6 – Reply comments are due on the 9-1-1 Non-Service Initialized Device NPRM.
Jul. 6 – Reply comments are due on Eligible Services List for E-Rate 2016.
Jul. 20 – PRA comments are due on the Open Internet Order.
Jul. 27 – Comments are due on FirstNet Draft RFP.
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 – 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. 29 – Copyright Statement of Accounts is due. | 
David George and Bill Noyes
