Today's Regulatory Mix:  FCC Mobility Fund Phase II Coverage Maps, FCC Annual Recordkeeping Reporting Requirements,  FCC SBA National Ombudsman

FCC Mobility Fund Phase II Coverage Maps 

The FCC’s Rural Broadband Auctions Task force released a Public Notice proposing to release certain mobile broadband coverage data submitted pursuant to the FCC’s  MF-II Challenge Process Order.  Specifically, the Task Force proposes to release coverage maps showing the 4G LTE coverage of each of the 48 mobile service providers that filed data in response to the Challenge Process Order.  The maps would show coverage aggregated across spectrum bands and would show only 4G LTE coverage as reported for the MF-II collection. The coverage data would neither show a provider’s complete and current mobile broadband coverage nor reveal information on the spectrum bands that comprise its coverage meeting the MF-II specifications. The data to be released would not include link budget or clutter information. The Task Force believes that releasing the MF-II coverage data would allow the public to have a fuller understanding of the issues that the FCC faced in the MF-II proceeding and would improve the FCC’s consideration of how to improve the collection of mobile broadband data going forward. The Digital Opportunity Data Collection proceeding 

Parties that submitted MF-II coverage data have until February 27, 2020 to object to the release of their own data.  Parties objecting must explain why publicly releasing these data will reveal information they have not already made available to the public and will harm them competitively, including a specific and detailed description of the extent of that harm. Parties objecting also should specify which components of the data to be released their objections concern.  Parties that believe that this information should be made public are welcome to file comments supporting release of the data. If the FCC receives no objections, it will publicly release these data on March 2, 2020.  

FCC Annual Recordkeeping Reporting Requirements 

The FCC issued a Public Notice reminding service providers and equipment manufacturers that are subject to its disability accessibility rules of their obligation to maintain records of their efforts to implement these requirements and to file their annual recordkeeping compliance certifications and required contact information no later than April 1, 2020 in the Recordkeeping Compliance Certification and Contact Information Registry (RCCCI Registry).  Among other things, the certificate states that the provider has established operating procedures that are adequate to ensure compliance with the recordkeeping rules and that it is keeping records accordingly.  It must be supported with an affidavit or declaration under penalty of perjury, signed and dated by the authorized officer of the company with personal knowledge of the representations provided in the company's certification, verifying the truth and accuracy of the information therein.   Inteserra Briefing Service subscribers see Briefing dated 1/31/13.   

FCC SBA National Ombudsman 

The FCC issued a Public Notice reminding small entities that the Office of the National Ombudsman within the U.S. Small Business Administration (SBA), is available to assist small entities with federal agency enforcement and compliance matters.  The Ombudsman’s Office and ten regional Small Business Regulatory Fairness Boards (“RegFair Boards”) facilitate meaningful dialogue between federal agencies and small entities. One avenue for assistance is the Ombudsman’s written comment process. Using a one-page Federal Agency Appraisal Form, a small business may submit to the Ombudsman’s Office any comments concerning a federal agency’s enforcement action. The Ombudsman then forwards this form, along with any additional documentation, to the agency for review. Small businesses may request expedited treatment of an enforcement action against them, when they believe that delay may threaten the economic viability of their businesses. 

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The Regulatory Mix, Inteserra’s blog of telecom related regulatory activities, is a snapshot of PUC, FCC, legislative, and occasionally court issues that our regulatory monitoring team uncovers each day. Depending on their significance, some items may be the subject of an Inteserra Briefing.