Author Archive

Auction 103 Short Form Application Filing Window Opens Today and List of Upfront Payments and Minimum Opening Bids

The filing window for Short-Form Applications for participation in Auction 103 (Upper 37 GHz, 39 GHz, and 47 GHz bands) opens today, August 26, 2019. The Short-Form Applications are due by September 9, 2019, at 6:00 PM, ET.  The Federal Communications Commission released a list of upfront payments and minimum opening bids by PEA for […]

REMINDER: Hearing Aid Compatibility Certifications Due October 3, 2019

Filing Window Opens September 3, 2019 Wireless service providers (including de minimis wireless service providers) must file their annual Hearing Aid Compatibility Certifications with the FCC for the 2018 reporting period by October 3, 2019.  The filing window will open September 3, 2019 and will contain a link to the new FCC Form 855 and instructions at: This new certification replaces the […]


Due October 15, 2019 Covered 911 Service Providers must file the 911 Reliability Certification with the FCC by October 15, 2019 via the FCC’s online system at:  The 911 Reliability Certification System is now open for the annual filing. Covered 911 Service Providers are providers of 911, E911, or NG911 capabilities such as call routing, automatic location […]

Applications Due September 9 for Auction of Licenses in the 37 GHz, 39 GHz and 47 GHz Bands (Auction 103)

Public Notice – AU Docket No. 19-59 On July 11, 2019, the Federal Communications Commission (“FCC” or the “Commission”) released the Public Notice announcing application and bidding procedures for the upcoming Auction 103 of Upper Microwave Flexible Use Service (“UMFUS”) licenses in the 37 GHz, 39 GHz, and 47 GHz bands.  The Public Notice establishes an […]

FCC Seeks Comment on Treatment of Home-Based Businesses Locations Under A-CAM

On May 6, two of our firm’s clients filed a Petition for Clarification or Declaratory Ruling (view here) seeking guidance from the FCC on the definition of locations under the Alternative Connect America Cost Model (A-CAM) for residences that also serve as businesses. Specifically, the Petition notes that a Frequently Asked Questions (FAQ) document released […]

FCC Seeks Comment on Petition to Prevent Overbuilding of Existing Fiber Networks with E-Rate Funds

On May 22, 2019, three of our firm’s clients filed a Petition for Rulemaking (view here) asking that the Federal Communications Commission initiate a proceeding and change its rules to prohibit or discourage the use of USF E-Rate money to overbuild existing fiber networks, especially fiber networks that have been constructed with USF support.  The […]

Lower 700 MHz License Construction and Renewal Deadline Reminder

The deadline to meet the final construction requirement and renew certain Lower 700 MHz licenses (A Block, B Block, and C Block) is Thursday, June 13, 2019. By that date, a Lower 700 MHz A or B Block licensee must have constructed facilities to provide signal coverage and offer service to at least 70 percent of its license […]

Common Carrier Annual Employment Report

FCC Form 395 Due May 31, 2019 Common carrier licensees or permittees with sixteen (16) or more full-time employees must file an annual employment report (FCC Form 395) with the Federal Communications Commission by May 31st of each year. If the filing concerns a licensee that had fewer than sixteen (16) full-time employees during the […]

FCC Seeks Comment on Competitive Bidding Procedures for Auction 103

(Upper 37 GHz, 39 GHz, and 47 GHz) (AU Docket No. 19-59) The Federal Communications Commission (“FCC” or “Commission”) has released a Public Notice seeking comment on competitive bidding procedures for the incentive auction of Upper Microwave Flexible Use (“UMFUS”) licenses in the Upper 37 GHz (37.6-38.6 GHz), 39 GHz (38.6-40 GHz), and 47 GHz […]

USDA Opens Application Window for Rural Broadband Pilot “ReConnect” Program

The U.S. Department of Agriculture’s (“USDA”) Rural Utilities Service (“RUS”) announced that it will begin accepting applications for its rural broadband pilot program, the ReConnect Program, on April 23, 2019 through  The ReConnect Program will award up to $600 million to help build broadband infrastructure throughout rural America.  The program will make 3 types of awards available, each with […]