FCC filings by wispa

Below is a list of filings that WISPA has submitted to the Federal Communications Commission.

2017
Date
Type of Filing
January 24, 2017
WISPA filed the attached Reply Comments with the FCC today regarding making the 3700-4200 MHz band more conducive to spectrum sharing between fixed satellite and fixed terrestrial use.  Thanks to my partner David Rines for taking the laboring oar on these Comments as well as the initial Comments WISPA filed on January 9.  Thanks also to Fred Goldstein for his technical contributions.
January 24, 2017
WISPA and ViaSat collaborated on the attached ex parte letter, which reiterates opposition to a request by the state of New York to take funds set aside for CAF and allocate it to awardees of its state broadband fund.  The objections are based on a New York process that is not technology-neutral and by a concern of fundamental fairness to other states.
January 3, 2017
United States Telecom Association (“USTelecom”) petitioned the FCC for reconsideration of the Commission’s Order concerning Protecting the Privacy of Customers of Broadband and Other Telecommunications Services.
January 3, 2017
WISPA filed Reply Comments to the FCC's 2016 Biennial Review of Telecommunications Regulations
2016
Date   Type of Filing
December 19, 2016
FCC Commissioners Pai & O'Rielly respond to the 12/14/16 joint letter from WISPA, CCA, NCTA and ACA.
December 14, 2016
A joint letter from WISPA, CCA, NCTA and ACA urges the FCC to extend the exemption relieving small broadband providers from the enhanced transparency rules established by the 2015 Open Internet Order.
December 6, 2016
WISPA filed the attached Reply Comments today recommending specific conditions on school districts that seek to use E-rate funds for off-campus locations such as residences.  The conditions are designed to ensure there is no double-funding from E-rate and other sources such as Lifeline and CAF, that areas do not already receive 4/1 Mbps speeds and that private investment is not discouraged or undermined.
November 3, 2016
WISPA filed Comments today generally supporting the use of E-rate subsidies for the provision of Internet service to off-campus locations, with important conditioned designed to avoid discouraging private investment and he use of subsidies where broadband is funded through CAF.  The Comments also support the use of spectrum for E-rate activities.  These are intentionally high-level, as we want to work with stakeholders to develop a more detailed regulatory structure that would support individualized waivers.
November 2, 2016
The FCC released its 219-page Report and Order and accompanying rules on the obligations of broadband providers to protect their customers’ privacy through transparency, choice and data security.  CLICK HERE FOR THE FULL REPORT | CLICK HERE FOR THE WISPA SUMMARY
October 31, 2016
WISPA filed Reply Comments with the FCC today opposing efforts by the Pennsylvania Public Utilities Commission to obtain $28 million in direct federal CAF support, which it would apparently make available only to ILECs in the state.  This follows a similar request by New York State to take federal CAF money out of the reverse auction – instead, these two states ask the FCC to provide then with all of the support designated for bidding through reverse auction, and the states would then dole out the money.
October 24, 2016
WISPA filed an ex parte presentation to supplement its filings in WC Docket No. 16-106: Protecting the Privacy of Customers of Broadband and Other Telecommunications Services.
September 12, 2016
WISPA filed comments on the Proposed Extension of Part 4 of the Commission’s Rules Regarding Outage Reporting to Interconnected Voice Over Internet Protocol Service Providers and Broadband Internet Service Providers.  WISPA built on our earlier request for a small business exemption from any broadband outage reporting the rules the FCC may adopt.  The Reply Comments suggest that a small provider be required to only report “hard down” outages that affect at least 1,000 customers for 15 hours, and that degradation in service and outages on upstream networks need not be reported.
September 12, 2016
WISPA filed comments opposing the FCC’s unsupported estimates of time and resource burdens associated with the “enhanced” disclosure obligations that the FCC adopted in the 2015 Open Internet Order.  The Comments note that the FCC has not cited the underlying record, which supports a permanent exemption.
September 6, 2016
WISPA filed an opposition to certain aspects of the petitions for reconsideration of the Further Notice of Proposed Rulemaking in the matter of Connect America Fund ETC Annual Reports and Certifications Rural Braodband Experiments.
September 6, 2016
WISPA filed comments in the matter of Inquiry Concerning the Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion and Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of The Telecommunications Act of 1996, as Amended by the Broadband Data Improvement Act.
July 21, 2016
WISPA submitted comments to the FCC regarding the rules proposed in the FNPRM for competitive bidding in Phase II of the Connect America Fund program.
July 12, 2016
WISPA filed a letter advising that they met with Carol Mattey, Alex Minard, Heidi Lankau and Katie King of the Wireline Competition Bureau to discuss the rules proposed in the FNPRM for competitive bidding in Phase II of the Connect America Fund program.
July 6, 2016
WISPA filed a letter with the FCC regarding the Commission’s proposal to adopt prescriptive rules for protecting broadband customers’ privacy.
June 16, 2016   WISPA filed a letter advising that they met with Edward Smith, Legal Advisor to Chairman Tom Wheeler, to discuss the draft order on circulation regarding Globalstar's proposed Terrestrial Low Power Service ("TLPS").
June 13, 2016   WISPA filed a letter advising that they met with Johanna Thomas, Legal Advisor to Commissioner Jessica Rosenworcel, to discuss the draft order on circulation regarding Globalstar's proposed Terrestrial Low Power Service ("TLPS"). 
June 10, 2016   WISPA filed a letter advising that they met with Daudeline Meme, Legal Advisor to Commissioner Mignon Clyburn, and David Nayer, Commissioner Clyburn's legal intern, to discuss the draft order on circulation regarding Globalstar's proposed Terrestrial Low Power Service ("TLPS").
June 9, 2016   WISPA filed a letter advising that they spoke by telephone with Erin McGrath, Legal Advisor to Commissioner Michael O'Rielly, to discuss the draft order on circulation regarding Globalstar's proposed Terrestrial Low Power Service ("TLPS").
June 6, 2016   WISPA replies to certain of the initial Comments filed in response to the Notice of Proposed Rulemaking (“NPRM”) in the Amendment of Part 15 of the Commission’s Rules For Unlicensed White Space Devices.
May 27, 2016   WISPA comments on Protecting the Privacy of Customers of Broadband and Other Telecommunications Services. 
May 24, 2016   WISPA opposes the Petition for Waiver of 47 C.F.R. § 90.353(b) and Request for Extension of Time and for Expedited Treatment filed April 15, 2016 by PCS Partners, L.P. (“PCSP”).
May 19, 2016   WISPA filed a letter advising that they met with Amy Bender, Legal Advisor to Commissioner Michael O'Rielly, to discuss the proposed framework for competitive bidding in Phase II of the Connect America Fund ("CAF") program.
May 6, 2016   WISPA requests partial reconsideration of the March 2, 2016 Report and Order in Revision of Part 15 of the Commission’s Rules to Permit Unlicensed National Information Infrastructure (U-NII) Devices in the 5 GHz Band.
May 2, 2016   WISPA filed a letter advising that they, along with other interested parties, met with Carol Mattey, Alex Minard, and Heidi Lankau of the Wireline Competition Bureau and Neil Dellar and Suzanne Tetreault of the Office of General Counsel.  The purpose of the meeting was to discuss the Connect America Fund (“CAF”) Phase II competitive bidding process and the proposed requirement that winners in the process provide a Letter of Credit (“LoC”).
March 10, 2016   WISPA replies to those portions of the Opposition to Petitions for Reconsideration of the National Association of Broadcasters (“NAB”) filed that oppose WISPA’s Petition for Partial Reconsideration.
February 29, 2016   WISPA opposes certain petitions for reconsideration filed in the Amendment of Part 15 of the Commission’s Rules for Unlicensed Operations in the Television Bands, Repurposed 600 MHz Band, 600 MHz Guard Bands and Duplex Gap, and Channel 37, and Amendment of Part 74 of the Commission’s Rules For Low Power Auxiliary Stations in the Repurposed 600 MHz Band and 600 MHz Duplex Gap, and Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auctions.  
February 26, 2016   WISPA submits Reply Comments in response to certain of the initial Comments filed in Use of the Spectrum Bands Above 24 GHz for Mobile Radio Services, Establishing a More Flexible Framework to Facilitate Satellite Operations in the 27.5-28.35 GHz and 37.5-40 GHz Bands, Petition for Rulemaking of the Fixed Wireless Communications Coalition to Create Service Rules for the 42-43.5 GHz Band, Amendment of Parts 1, 22, 24, 27, 74, 80, 90, 95, and 101 To Establish Uniform License Renewal, Discontinuance of Operation, and Geographic Partitioning and Spectrum Disaggregation Rules and Policies for Certain Wireless Radio Services, and Allocation and Designation of Spectrum for Fixed-Satellite Services in the 37.5-38.5 GHz, 40.5-41.5 GHz and 48.2-50.2 GHz Frequency Bands; Allocation of Spectrum to Upgrade Fixed and Mobile Allocations in the 40.5-42.5 GHz Frequency Band; Allocation of Spectrum in the 46.9-47.0 GHz Frequency Band for Wireless Services; and Allocation of Spectrum in the 37.0-38.0 GHz and 40.0-40.5 GHz for Government Operations. 
February 12, 2016   American Cable Association (“ACA”) and WISPA filed a letter advising that they met with Alex Minard and Heidi Lankau of the Wireline Competition Bureau and Neil Dellar of the Office of General Counsel.  The purpose of the meeting was to review ACA/WISPA’s proposal, submitted in a February 9, 2016 ex parte letter, that the Commission adopt alternative criteria by which a bank would be deemed eligible to issue an acceptable Letter of Credit (“LoC”) for the Connect America Fund Phase II competitive bidding process.
February 9, 2016   WISPA filed a letter to urge the Commission to act on the Modified Consensus Proposal in advance of the upcoming March 2, 2016 deadline by which new equipment must be certified under the rules adopted in the First Report and Order.
February 9, 2016   WISPA filed a letter advising that they had filed an ex parte letter expressing concerns that two financial qualification requirements the Commission is considering for the Connect America Fund (“CAF”) Phase II competitive bidding process will deter, if not preclude, smaller experienced service providers (“SESPs”) from participating, undercutting the Commission’s objective to bring fixed broadband service to unserved areas cost effectively.
February 8, 2016   WISPA filed a letter advising that they met separately with Stephanie Weiner, Legal Assistant to Chairman Tom Wheeler, Travis Litman, Legal Assistant to Commissioner Jessica Rosenworcel, Nick Degani, Legal Assistant to Commissioner Ajit Pai, and Amy Bender, Legal Assistant to Commissioner Michael O'Rielly.  At each meeting they discussed Mr. Carr's recent testimony on behalf of WISPA before the Subcommittee on Communications, Technology, Innovation and the Internet of the U.S. Senate Committee on Commerce, Science, & Transportation, and emphasized WISPA's concerns about the proposed framework for competitive bidding in Phase II of the Connect America Fund ("CAF") program.
January 21, 2016   WISPA filed a letter advising that they met separately with Edward Smith, Legal Assistant to Chaimrnn Tom Wheeler; Johanna Thomas, Legal Assistant to Commissioner Jessica Rosenworcel; Brendan CarT, Legal Assistant to Commissioner Ajit Pai; and Commissioner Michael O'Rielly and his Legal Assistant Erin McGrath.  The purpose of the meeting was to present WISPA's views and concerns about a Notice of Proposed Rulemaking ("NPRM") on circulation that would propose changes to rules permitting professional installation of TV white space devices.
January 12, 2016   WISPA filed comments replying to the Google Response regarding the methodology for establishing and implementing Grandfathered Wireless Protection Zones for registered fixed operations in the 3650-3700 MHz band.
2015
Date   Type of Filing
December 28, 2015   WISPA filed comments in response to the Public Notice adopted by the Wireless Telecommunications Bureau regarding the
methodology for establishing and implementing Grandfathered Wireless Protection Zones for registered fixed operations in
the 3650-3700 MHz band.
December 23, 2015   WISPA requested reconsideration of two actions taken by the Commission regarding Amendment of Part 15 of the Commission’s Rules
for Unlicensed Operations in the Television Bands, Repurposed 600 MHz Band, 600 MHz Guard Bands and Duplex Gap, and Channel 37,
 and Amendment of Part 74 of the Commission’s Rules For Low Power Auxiliary Stations in the Repurposed 600 MHz Band and 600 MHz
Duplex Gap Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auctions.
December 17, 2015   WISPA filed a letter stating that a group of interested parties met with Carol Mattey, Alex Minard, and Heidi Lankau of the Wireline
Competition Bureau and Neil Dellar of the Office of General Counsel.  The purpose of the meeting was to discuss the proposed
framework for the Connect America Fund (“CAF”) Phase II competitive bidding process and financial qualifications for smaller
service providers to participate in the process.
December 10. 2015   WISPA filed a letter stating that they met with Edward Smith, Legal Advisor to Chairman Tom Wheeler, to summarize WISPA's views
on Globalstar's proposed Terrestrial Low Power Service ("TLPS").
November 24, 2015   WISPA filed a letter to express their support for an extension of the June 2, 2016 deadline by which all U-NII-3 equipment sold in the
United States must be compliant with Section 15.407.
November 23, 2015   WISPA filed a letter stating that a group of interested parties met with Carol Mattey, Deputy Chief of the Wireline Competition Bureau,
and Claude Aiken, Associate General Counsel.  The purpose of the meeting was to present WISPA's views and concerns about the proposed
order on circulation that would establish the framework for competitive bidding in Phase II of the Connect America Fund ("CAF") program.
November 5, 2015   WISPA requested a waiver of Section 15.37(h) to extend by three months the deadline by which Part 15 devices in the
5725-5850 MHz band must meet new equipment certification requirements.
October 22, 2015   WISPA filed a letter concerning the Revision of Part 15 of the Commission's Rules to Permit Unlicensed National Information
Infrastructure (U-NJJ) Devices in the 5 GHz Band.
October 19, 2015   WISPA opposes and comments on the petitions for reconsideration of the Commission’s Report and Order adopting rules for the
Citizens Broadband Radio Service.
September 30, 2015   WISPA replied to comments on Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion,
and Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, as Amended by the
Broadband Data Improvement Act.
September 30, 2015   WISPA filed a letter supporting the amendment of Sections 101.109(c) and 101.147(s) of the Commission's Rules to allow channel sizes
of 80 MHz, 160 MHz and 320 MHz in the 21.2-23.6 GHz band ("23 GHz Band"), consistent with the proposal made by Mimosa Networks Inc.
September 30, 2015   WISPA filed comments concerning the Notice of Proposed Rulemaking issued June 16, 2015. 
September 21, 2015   WISPA filed comments on the request for waiver of certain Part 15 rules filed by Deere & Company.
September 15, 2015   WISPA filed comments on Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion,
and Possible Steps to Accelerate Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, as Amended by the
Broadband Data Improvement Act.
September 9, 2015
  WISPA filed comments with the FCC re-affirming its request for a permanent exemption from the FCC’s new open Internet disclosure rules.
August 5, 2015
  WISPA filed comments seeking to make permanent the FCC’s exemption for small businesses to comply with the new open Internet disclosure
obligations.
June 30, 2015
  WISPA filed a letter with the FCC proposing procedures for the CAF Phase II competitive bidding process that is scheduled to take place
next year.
June 26, 2015
  WISPA filed Reply Comments with the FCC regarding the FCC’s inquiry into LTE-U/LAA trends
June 11, 2015
  WISPA filed with the FCC in response to the FCC’s questions about LTE-U/LAA technology
May 18, 2015
 
WISPA filed Reply Comments supporting the FCC’s proposed definition of “commence operations” for TV white space rules, and opposing
the views of the mobile wireless industry.
May 1, 2015
 
WISPA files a Stay request with the FCC while Court challenges to the Title II reclassification and the general Internet conduct standards are
litigated and resolved.
April 27, 2015
 
WISPA files a petition with the D.C. Circuit Court Appeals requesting relief from the FCC’s Open Internet Rules.
April 13, 2015
  WISPA filed reply comments with the FCC reiterating its position seeking less restrictive financial requirements for CAF Phase II. 
March 31, 2015
  Ex Parte filed seeking an exemption for small providers of 100,000 subscribers or less from any new USF contributions the FCC may impose in its
ongoing rulemaking proceeding.