CommLawBlog (Courtesy of Fletcher, Heald & Hildreth)

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Still a work in progress, but an excellent opportunity both to see what the FCC has in mind  and also to suggest possible improvements to the form before it takes final shape. A couple of weeks ago we reported on a Federal Register notice announcing the start of a two-month period for the filing of comments about a new FCC form (Form 2100, Schedule 381, to be exact - a/k/a “Certification of TV Broadcast Licensee Technical Information in Advance of Incentive Auction”). We noted then that no copy of the form was included in the Federal Register notice and that our...
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Wi-Fi jammers, too! Having recently spanked Marriott for $600K for interrupting private Wi-Fi use at one of its hotel properties – concern about which presumably prompted Marriott to seek formal guidance about just how far they can go in managing Wi-Fi use at their venues – the Commission has issued another of its ever-popular “Enforcement Advisories” warning against the use of jammers to interfere with cellphone, Wi-Fi or GPS devices. (Similar advisories were issued in 1999, 2005, 2011 and 2012, along with Spanish and Mandarin versions of the 2012 notice.) The use of jammers is, of course, a very tempting way to...
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Agency looks to tighten up vague standards that have led to inconsistent access decisions. If you as a broadcaster, producer, or artist want to head into a congressionally-designated wilderness area to create some programming (both newsgathering and other programming), you will likely have to get a permit to do so from the National Forest Service (NFS). And yes, the power to require a permit also encompasses the power to require a fee for that permit, so you can expect to have to pay for the privilege. For years the standards imposed by the NFS on requests for such permits have been considerably...
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Mitch came to the law the long way around and relatively late in life. Mitchell Lazarus, FHH veteran and CommLawBlog regular, has announced he will retire at the end of this year. But not completely. Mitch will stay on the FHH letterhead as Of Counsel, will keep an office in our suite, and can still be reached through his FHH phone number and email address. We will, of course, also keep his suite in the CommLawBlog bunker ready for him. IMPORTANT: Mitch’s active clients should have received an email about this transition. If you did not, please contact him at lazarus@fhhlaw.com. Mitch came...
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New “Submit a Non-Docketed Filing” module allows some filers to eschew paper. In a move presumably designed to make everybody’s lives easier, the Commission has expanded its Electronic Comment Filing System (ECFS) to accept a wide range of filings that previously could be filed only on paper. That’s good news. But before you take advantage of this new opportunity, be sure you’re familiar with the fine print. Historically, ECFS has been available only for materials being submitted in docketed proceedings. Since many FCC activities don’t involve such proceedings, paper filings have continued to be the order of the day in many areas....
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As we reported just before Thanksgiving, Congress passed the STELA Reauthorization Act of 2014 (STELAR), which the President promptly signed just after Thanksgiving (also as we reported). STELAR is a law with lots of provisions affecting lots of different areas of the video universe, as Paul Feldman’s pre-Thanksgiving post revealed. Attentive readers may have noticed the following, tucked in toward the end of that post: Delayed Application of JSA Attribution Rule. Also as we reported in April, the Commission has determined that certain TV joint sales agreements (JSAs) will now give rise to attributable interests under the multiple ownership rules. As...
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A couple of months ago we reported on two proceedings, initiated simultaneously, looking into possible solutions to the problems that the upcoming repack of the spectrum will cause to wireless microphone users and manufacturers as well as various other users of the TV spectrum. While technically separate and distinct dockets, the two proceedings have obviously been linked from Day One. And now the FCC has announced, in a single consolidated order, that the comment deadlines for both proceedings have been extended. As a result, comments in either or both of the dockets may be filed by February 4, 2015; reply...
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But the FCC isn’t planning to give tower owners much slack as a result. If you’re responsible for a tower subject to lighting requirements imposed by the Federal Aviation Administration, your life may be getting a bit easier early next year. According to an advisory issued by the FCC’s Wireless Telecommunications Bureau, the FAA is modifying its notification process to allow folks reporting lighting outages to specify, in their initial notices, the amount of time they expect to need to get the outage fixed. We all know that the FAA imposes lighting requirements on certain tower structures, and the FCC adds extra...
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Last month we reported on the FCC’s disposition of a number of petitions for reconsideration in the rural call completion proceeding. In taking care of those petitions, the Commission tweaked its rules a bit, mainly in response to suggestions from USTelecom and ITTA. That action has now been published in the Federal Register, which means that those tweaks will become effective as of January 9, 2015. Note, however, that the “information collections” that the FCC has adopted in this proceeding – including both those adopted in the Report and Order a year ago and the changes in the recent order...
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Back in October we reported on a Notice of Inquiry seeking comments on the possible use of frequencies above 24 GHz for mobile services. According to a notice in the Federal Register, the deadlines for those comments have been extended. Comments are now due by January 15, 2015, and replies are due by February 17.
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Five more years of DBS, coming up! We recently reported on the passage of the STELA Reauthorization Act of 2014, affectionately referred to by the cognoscenti as “STELAR”. As expected, it didn’t take long for the President to sign off on it. According to the White House website, STELAR was signed into law on December 4.
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NPRM seeks to address effects of discontinuance of copper-based services on consumers, competition. As many readers doubtless know (and as we have previously reported), the IP transition is underway: telecom carriers are shifting away from time division multiplex (TDM) technology using traditional copper wires; instead, they are embracing Internet protocol (IP) technology using optical fiber and coaxial cable facilities. This shift will implicate a wide range of regulatory considerations which the FCC is already looking into. It will also affect consumers and competitive telecommunications providers who are used to the TDM/copper wire way of life. In a Notice of Proposed Rulemaking and...
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