The National Telecommunications and Information Administration (“NTIA”) has adopted a “Programmatic Waiver” of its letter of credit (“LOC”) requirement for subgrantees of funding under the $42.5 billion Broadband Equity, Access and Deployment (“BEAD”) program created by the Infrastructure and Investment Job Act (“IIJA”). This is big news for small and mid-size public and private entities
Telecom Policy
Little-Known Drone Radio Compliance Requirement Subject of FCC Rulemaking

Drones, or unmanned aerial vehicles (UAVs), are experiencing rapid growth throughout the world. In the United States, the FAA expects the recreational UAV fleet to reach almost 1.5 million units by 2024. Significant growth is also expected in commercial drones used for safety, delivery, and service operations, with the number of such aircraft expected to…
FCC Proposes New NG911 Rules


Last week, the Federal Communications Commission (FCC or Commission) released a draft Notice of Proposed Rulemaking (NPRM) to help facilitate the nationwide transition to Next Generation 911 (NG911). The Commission will vote on this NPRM at its Open Meeting on June 8th.
Background
In October 2021, the National Association of State 911 Administrators …
Treasury Releases Final Version of SLFRF/CPF Supplemental Broadband Guidance

The Treasury Department has released the final version of important compliance guidance applicable to broadband projects funded through SLFRF or CPF awards. The “SLFRF and CPF Supplemental Broadband Guidance” (“Guidance”) addresses several crucial issues relating to the use of SLFRF and CPF funds for broadband projects, including the crucial distinction of ISPs acting…
Ten Key Issues for Broadband Network Operating Agreements



While there is no one solution to deploying affordable broadband, broadband partnerships have emerged as an attractive option in many areas of the country; indeed, in some instances, partnerships may be the only feasible option.[1] Recognizing the attractiveness of broadband partnerships, Congress and many states have sought to encourage such partnerships to help accelerate…
Treasury Proposes Important New Guidance for SLFRF/CPF Broadband Projects
On March 28, 2023, the Treasury Department issued and invited comments on proposed compliance guidance applicable to broadband projects funded through SLFRF[1] or CPF[2] awards (“Proposed Guidance”).
The Proposed Guidance addresses a variety of important questions relating to the use of SLFRF and CPF funds for broadband projects, including:
- The crucial distinction between
…
Keller and Heckman Webinar: Navigating the FCC’s Universal Service Program: Compliance Requirements for Service Providers


On March 9, 2023, Keller and Heckman attorneys Greg Kunkle and Casey Lide presented a webinar titled “Navigating the FCC’s Universal Service Program: Compliance Requirements for Service Providers.”
The FCC’s Universal Service Fund (USF) program is one of the most significant regulatory issues faced by service providers. The USF assessment amount is substantial and penalties…
With Billions of Dollars of Broadband Funding at Stake, the Timing of the Challenge Process to the FCC’s Broadband Map Under Increasing Scrutiny



Just over a month ago, the FCC released its pre-production draft of its new Broadband Maps. The initial map is based on service availability data collected from broadband providers through the ongoing Broadband Data Collection (“BDC”) and reflects services available[1] as of June 30, 2022.[2]
The release of the Broadband Map initiated…
FCC Proposes Updated Network Outage Rules

The FCC adopted a Second Report and Order at its Open Meeting on November 17, promulgating rules requiring service providers to deliver more timely and actionable information to 911 facilities during network outages. The Commission hopes the new rules will streamline the network outage notification process and align the requirements imposed on different service providers.…
Overview of the FCC’s Broadband Data Collection Bulk Fabric Challenge Process



The Federal Communications Commission (“FCC” or “Commission”) completed its first Broadband Data Collection (“BDC”) on September 1, 2022.[1] The Commission is now accepting and evaluating bulk challenges to the FCC’s Broadband Serviceable Location Fabric (“Fabric”), which serves as the foundation for the FCC’s upcoming broadband data map. To ensure the most accurate broadband map…