Daily Ex Parte, Aug 27, 2025
Aetherworks Labs (Response to AST SpaceMobile), altafiber/Hawaiian Telecom (pushing back on TV National Ownership reform), Voice on the Net Coalition (robocall proceedings)
The Daily ExParte
Filers
Cincinnati Bell Extended Territories LLC dba altafiber, Hawaiian Telcom Services Company, Inc. — Pushing the "social contract" model as a flexible, measured approach to easing television ownership restrictions, specifically the 39% national ownership cap.
Voice on the Net Coalition — robocall mitigation and numbering policy proceedings
Aetherworks Labs Inc. (17210256 Canada Inc.) — Filing in response to an August 3, 2025 request from AST SpaceMobile regulatory staff.
Cincinnati Bell Extended Territories LLC dba altafiber, Hawaiian Telcom Services Company, Inc.
Proceeding(s): 25-133, 17-318
Date of Meeting: August 25, 2025
Date Disseminated: August 27, 2025
Participants:
altafiber and Hawaiian Telcom: Ted Heckmann (Vice President – Regulatory & Government Affairs), Kevin Mann (Director-Regulatory Affairs), and Jonathan Bond (Director – Product Strategy).
Breisach Cordell PLLC (Counsel for altafiber and Hawaiian Telcom): Eric Breisach and Lisa Chandler Cordell.
FCC: Marcus Maher (Senior Legal Advisor, Office of Commissioner Trusty).
Summary of Discussion:
Representatives of altafiber and Hawaiian Telcom met with staff from Commissioner Trusty's office to propose a "social contract" model as a flexible, measured approach to easing television ownership restrictions, specifically the 39% national ownership cap.
altafiber argued that major broadcasters, particularly Nexstar and Sinclair, present contradictory narratives. While they claim to the Commission that they face "economic Armageddon" without deregulation, they simultaneously report record revenues, earnings, and free cash flow to investors. altafiber presented data showing that a majority of these broadcasters' revenues (55%-62%) come from retransmission consent fees paid by MVPD subscribers. They highlighted that between 2020-2024, Nexstar and Sinclair generated billions in free cash flow and returned hundreds of millions of dollars to shareholders annually, undermining their claims of financial hardship.
The filers contended that the primary motivation for lifting the ownership cap is financial gain through consolidation, citing the recent bidding war for TEGNA. They pointed to Nexstar's "Consolidation Playbook," which explicitly states that an immediate priority after acquiring stations is to migrate them to Nexstar's higher-rate retransmission consent agreements. altafiber warned that unchecked consolidation would lead to an immense financial windfall for broadcasters at the direct expense of consumers, who already provide more than half of their revenue.
As a solution, altafiber proposed that the FCC use voluntary social contracts for any broadcaster seeking a waiver of the ownership rules, rather than a permanent rule change that they argue would likely be overturned in court. Drawing a parallel to the FCC's use of social contracts during cable rate deregulation in the 1990s, they outlined a framework that would benefit the Commission, broadcasters, and consumers.
The proposed social contract structure would include:
A 7-year term for any waiver granted.
Mandatory Retransmission Consent Rate Reductions: As a condition of the waiver, the broadcaster would commit to a schedule of rate reductions for all its stations in the affected markets:
Year 1: 25% reduction from a January 1, 2024 baseline.
Year 2: 40% total reduction.
Year 3: 50% total reduction.
Years 4-7: Annual increases capped at the Consumer Price Index (CPI).
Consumer Pass-Through: MVPDs would be required to pass 100% of these savings through to their subscribers.
Localism Commitments: The broadcaster would have to meet minimum requirements for local news programming, expenditures, and local staffing.
Public Process: All proposed social contracts would be subject to a Public Notice and comment period.
End-of-Term Review: After seven years, the Commission could use the data gathered to inform a permanent rulemaking decision.
altafiber concluded by warning that if the Commission raises or eliminates the national ownership cap without such consumer protections, it will trigger a "flood of consolidation" that will result in rapid, significant, and likely irreversible harm to consumers through increased retransmission consent fees.
Source: [NOTICE OF EXPARTE, Cincinnati Bell Extended Territories LLC dba altafiber, Hawaiian Telcom Services Company, Inc., https://www.fcc.gov/ecfs/document/1082657509482/1]
Voice on the Net Coalition
Proceeding(s): 17-59, 17-97, 21-402, 13-97, 07-243, 20-67, 16-155
Date of Meeting: August 25, 2025
Date Disseminated: August 27, 2025
Participants: Representatives from the Voice on the Net Coalition (VON), including Paula Boyd (Microsoft), Darah Franklin (Google), Dmytro Kulyk (Nextiva), Jennifer Best Vickers, Paul Kenefick, and Erin Emmott (Twilio), Olive Morris and Harold Lee (Telnyx), Marie Chambarlhac (Dialpad), Brendan Kasper (8X8), and counsel Glenn S. Richards and Lee Petro, met with FCC Commissioner Olivia Trusty and her senior legal advisor, Marcus Maher.
Summary of Discussion:
The Voice on the Net Coalition (VON) met with Commissioner Trusty's office to discuss its positions on several robocall mitigation and numbering policy proceedings. While supportive of the FCC's efforts to combat illegal traffic through initiatives like STIR/SHAKEN, VON highlighted four key unresolved issues:
Know Your Customer (KYC) Obligations: VON expressed significant concern over the lack of clear standards for KYC obligations. They argued that defining these standards through enforcement actions, such as citing the Lingo consent decree in a recent Notice of Apparent Liability, is improper and circumvents required notice-and-comment rulemaking. To address this ambiguity and protect providers acting in good faith, VON recommended that the FCC clarify that fines should only be imposed when a voice service provider has actual knowledge of illegal traffic on its network and fails to mitigate it.
Transition to All-IP Networks: While VON is encouraged by the Notice of Proposed Rulemaking regarding call authentication on non-IP networks, it remains concerned that many calls originating with a STIR/SHAKEN signature become unsigned when they traverse legacy, non-IP networks. VON argued that any policy allowing providers to delay the transition to all-IP networks hinders robocall mitigation, impairs the nationwide upgrade to NG911, and fosters a system of unnecessary charges. Consequently, VON urged the FCC to establish a firm deadline for all voice service providers to upgrade their networks to all-IP and to encourage local exchange carriers to negotiate reasonable IP interconnection agreements.
Wrongful Blocking and Mislabeling: VON raised ongoing concerns about the blocking and mislabeling of lawful and wanted calls. The coalition reiterated its opposition to the mandated use of SIP Code 603+ for call blocking notifications, stating that SIP Code 608 should have been permitted as a viable alternative. Despite this, VON members are actively working within the industry on solutions and redress options. They urged the FCC not to extend the implementation deadline for 603+ and warned they might seek further FCC intervention if the entities responsible for blocking propose solutions that unnecessarily increase costs for service providers.
Direct Access to Numbers for VoIP Providers: VON strongly recommended that the FCC reject proposed restrictions on interconnected VoIP providers' direct access to telephone numbers. The coalition argued such rules would be anticompetitive and would not effectively reduce illegal robocalls. VON asserted that any new numbering obligations should be applied consistently across the industry, regardless of the technology used. To counter the narrative that VoIP providers are the primary source of illegal robocalls, VON cited data from the Industry Traceback Group suggesting that traditional and wireless providers are traced back for illegal calls far more frequently than VON members.
Source: [NOTICE OF EXPARTE, Voice on the Net Coalition, https://www.fcc.gov/ecfs/document/10827667721086/1]
Aetherworks Labs Inc.
Proceeding(s): 23-65, 22-271
Date of Meeting: The filing is a written submission, and no specific meeting date with the FCC was mentioned.
Date Disseminated: August 27, 2025
Participants: The ex parte was submitted by William Aidan Sergei Rayburn, Founder & CEO of Aetherworks Labs Inc. (17210256 Canada Inc.). The document states it was prepared in response to an August 3, 2025 request from AST SpaceMobile regulatory staff, including Federico Fawzi, Abel Avellan, and Justin Henrie. No FCC staff were mentioned as participants.
Summary of Discussion:
Aetherworks Labs Inc. submitted a technical package to describe its "carrier-controlled, body-integrated uplink node" designed to operate within the FCC's Supplemental Coverage from Space (SCS) framework (FCC 24-28). The filing's purpose is to establish Aetherworks' technology as a viable, reproducible, and safe uplink endpoint for SCS services. Aetherworks states that no rule changes are being requested.
The submission was prompted by a request from AST SpaceMobile and is intended to show support for SCS leasing constructs, such as the one between AT&T and ASTS.
Key technical and validation points presented in the filing include:
Thermal Safety: The body-integrated device has been proven to be thermally safe, with testing demonstrating a nominal temperature change (ΔT) of ≤ 1.8 °C and a stressed change of ≤ 2.5 °C. These results were validated with probe calibration.
Performance and Validation: Over-the-air (OTA) performance was benchmarked against a 10 dB planning threshold, showing strong agreement (±2 dB) between controlled chamber tests and real-world field performance. The company successfully logged orbital acknowledgments on August 20, 2025, and confirmed the reproducibility of its results using HARQ and MRC repetition strategies.
Manufacturing and Quality Control: Engineering Validation Testing (EVT) was completed in August 2025. The company reports meeting high-quality manufacturing standards (σ_align ≤ 0.83 µm; Cp/Cpk ≥ 1.3–1.5) under established Quality Management System (QMS) gates. Statistical analysis using Wilson 95% lower bounds confirms a reproducibility of at least 80%, approaching 90%.
Regulatory Compliance: The device is designed for carrier control, utilizing low-power narrowband repetition and precise timing windows. This ensures a conservative posture regarding Power Flux-Density (PFD) and Out-of-Band Emissions (OOBE). Aetherworks asserts that its disclosures are structured to align directly with the FCC Form 608's SCS checkbox and associated requirements. The product is also described as "FDA-anchored," indicating it is designed with Food and Drug Administration standards in mind, which is relevant for a body-integrated device.
Source: [NOTICE OF EXPARTE, Aetherworks Labs Inc. (17210256 Canada Inc.), https://www.fcc.gov/ecfs/document/1082780590474/1]