FCC Sees Array of Telecom Regulation Revision Suggestions
Ditching the requirement to notify VoIP users it won't work without power and eliminating supposedly outdated reporting requirements were among suggestions by telecoms, the cable industry and others for the FCC's 2018 biennial review of telecom regulations. Comments in seven dockets, which had been due Jan. 17 (see 1812180002), were posted Monday due to an extension from the partial federal shutdown.
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Interconnected VoIP service users are notified frequently that the service won't work without power, so FCC Section 9.5(e)(2) requiring VoIP providers get and keep affirmative acknowledgement from customers that they know about power outage effects is pointless, NCTA said. It also urged repeal of Section 52.15(g)93)(iv)(C) of rules, requiring VoIP providers give state commissions a 30-day notification before applying for numbering resources from a numbering administrator. It said other voice service providers don't have the same requirement and it's not needed to prevent numbering exhaust.
Treating acquisition of spectrum below 1 GHz as an "enhanced factor" in transaction reviews is senseless now that everyone acknowledges the importance of mid-band and high-band spectrum for 5G, Verizon said. It said the enhanced factor review to spectrum below 1 GHz is inconsistent with the FCC's acknowledgement providers want mixes of spectrum bands. It also pushed for an easier approval process for block-for-block spectrum swaps that don't change a provider's net depth of ownership in that market and a repeal of penalties for failure to meet interim spectrum build requirements. Verizon's other recommendations included that spectrum leasing should require only notifying the FCC, not agency approval; an all-digital filing of Form 608 spectrum subleasing applications; and repeal of rules requiring pre-closing authorization for license transfers in pro forma transactions.
Complaining of burdensome administrative costs from USF contribution rules, the American Cable Association said the de minimis contributions threshold should be based on assessable revenue, not projected contributions, with that threshold adjusting over time. It said the VoIP contributions safe harbor should better approximate the percent of VoIP revenue coming from interstate and international services. ACA said the agency should streamline the traffic study filing requirements for smaller operators.
The FCC should amend Part 15 rules on how manufacturers present field strength measurement data as part of the equipment certification process, Cisco said. It also urged a "future-proof" of the measurements rule by looking into a different approach than the flat, stepped limits in use.
The Section 63.10(c) quarterly reports cover the same turf as the now-ended international traffic and revenue report and the streamlined annual Section 43.82 circuit capacity report, and the burdensome report should be eliminated, said telco law firm Kelley Drye. The Mobile & Wireless Forum -- a wireless safety consortium whose members include Apple, Cisco, Intel and Sony, according to its website -- said the FCC needs to harmonize its RF exposure limits with IEEE and global limits.
CKC Laboratories suggested changes to industrial, scientific and medical band device requirements and measurement procedures, and changes to Part 2.1033 application filing requirements, it said. UL asked that the Office of Engineering and Technology review and revise current field strength limits and their distances. UL said the agency should review and revise test site requirements, antenna requirements and measurement units for radiated emissions measurements below 30 MHz and look at a different antenna for radiated emissions measurements below 30 MHz.