The Daily Ex Parte, July 15, 2025
CBRS, Upper C-Band, ATSC 3.0, AWS-3, NextNav, Submarine cable systems
Filers
ARRL, The National Association for Amateur Radio -Part 97 amateur radio rules
Federated Wireless, Inc. - CBRS
ACA Connects - America's Communications Association - 17-84, 25-133, 25-59
Intrado Life & Safety, Inc. - 911 location accuracy
Zixi, LLC - Upper C-Band
Connected Devices for America Coalition - opposition to NextNav's petition
Pearl TV - ATSC 3.0 Mandated Transition
CTIA - AWS-3 spectrum auction
Enterprise Wireless Alliance - support for a waiver request (VHF public safety communications system)
Foreign Investment Review Section (FIRS), National Security Division (NSD) at the U.S. Department of Justice (DOJ), on behalf of the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (Committee or Team Telecom). Committee member agencies (DOJ, U.S. Department of Homeland Security, and the U.S. Department of Defense) - U.S. submarine cable systems
Hispanic Leadership Fund - Spanish-language Wireless Emergency Alerts
ARRL, The National Association for Amateur Radio
Proceeding(s): 25-133, RM-11828, RM-11759, RM-11767, 16-239
Date of Meeting: July 10, 2025
Date Disseminated: July 11, 2025
Participants:
ARRL, The National Association for Amateur Radio: David R. Siddall (Washington Counsel)
FCC, Wireless Telecommunications Bureau, Mobility Division: Roger Noel, Thomas Derenge, Thomas Reed, and Joshua Smith
Summary of Discussion:
ARRL met with staff from the FCC's Wireless Bureau to advocate for a comprehensive update to the Part 97 amateur radio rules. ARRL argued that many current rules are outdated and impede the core purpose of the amateur service, which is to foster experimentation, advance technical skills, and expand the reservoir of trained operators and electronics experts. They contended that modernizing the rules is essential to attract new generations to amateur radio and maintain America's leadership in wireless communications technology.
The discussion centered on proposals made in ARRL's comments for GN Docket No. 25-133, urging the FCC to initiate an omnibus proceeding to update the rules. Key points raised include:
Expanded Privileges for Technician Licensees: ARRL advocated for allowing beginner (Technician-class) licensees to use digital and voice modes on portions of the High Frequency (HF) bands. This change, related to petitions RM-11828 and RM-11759, would grant them access to local, regional, and worldwide communication capabilities, reflecting modern technology and band usage.
Modernizing Digital Mode Rules: The current system of using emission designators to define permitted modes is confusing and ill-suited for modern digital technologies. ARRL proposed considering alternatives to this framework.
Third-Party Traffic Reform: ARRL called for reforming § 97.115(a)(2), which requires diplomatic agreements for exchanging third-party messages. This is based on a 2003 change to the ITU International Radio Regulations that removed this requirement.
Additionally, ARRL identified five specific rules that it believes are obsolete and "ripe for deletion" through the FCC's "direct final rule" process, which would streamline their removal:
Symbol Rate Limitations (§ 97.307(f)): Delete the outdated symbol (Baud) rate and bandwidth limits, as previously proposed in the WT Docket No. 16-239 Further Notice of Proposed Rulemaking.
Digital Code Limitations (§ 97.309(a)): Remove obsolete restrictions on specific digital codes to permit the use of new and innovative digital modes, provided they remain publicly documented and unencrypted as required by existing rules.
Amplifier Power Limitation (§ 97.317(f)(2)): Eliminate the antiquated 15 dB RF input limitation on amplifier driving power, as proposed in RM-11767.
Paper License Replacement (§ 97.29): Delete the obsolete rule concerning the replacement of paper licenses.
Special Event Station Identification (§ 97.119(d)): Remove the obsolete requirement for operators using special event call signs to identify their station hourly.
Source: [NOTICE OF EXPARTE, ARRL, The National Association for Amateur Radio, https://www.fcc.gov/ecfs/document/10714210582157/1]
Federated Wireless, Inc.
Proceeding(s): 17-258
Date of Meeting: July 11, 2025
Date Disseminated: July 14, 2025
Participants:
Federated Wireless, Inc.: Kurt Schaubach, Jennifer McCarthy
FCC: William Holloway (Acting Legal Advisor to Commissioner Olivia Trusty)
Summary of Discussion:
In a meeting with staff from Commissioner Olivia Trusty's office, representatives from Federated Wireless, Inc. advocated for enhancements to the Citizens Broadband Radio Service (CBRS) framework to build upon its success and prepare the 3 GHz band for future technologies.
Federated Wireless began by highlighting the significant achievements of the CBRS band, noting it has become a global benchmark for spectrum sharing with over 400,000 deployed CBRS devices (CBSDs), more than 1,200 network operators, and no reported interference to incumbent users.
To further maximize the band's value, Federated Wireless proposed several near-term, practical improvements that could be implemented to increase efficiency and capacity while maintaining protections for incumbents. These include:
Increasing the heartbeat interval for certain CBSDs.
Converting static exclusion zones into dynamic protection areas (DPAs).
Expanding the use of clutter data in propagation models.
Introducing hybrid or dynamic monitoring approaches for DPAs.
Evaluating adjustments to aggregate interference protection criteria.
Looking toward the future, Federated Wireless urged the FCC to harmonize rules across the entire 3 GHz band (including AMBIT, CBRS, and C-Band) to support next-generation deployments like 6G. They argued that current fragmentation in service rules creates unnecessary complexity and cost. Specific recommendations include:
Permitting CBSDs to transmit at higher power levels.
Aligning the CBRS Out of Band Emission (OOBE) limits with those of adjacent bands. Federated Wireless stated that these changes would simplify network architecture, accelerate 5G/6G deployment, and enable the use of innovations such as RAN AI.
Federated Wireless asserted that these proposed changes would not negatively impact protected incumbent systems or the benefits afforded to lower-power users from the CBRS 2.0 rules adopted in 2024. To manage coexistence among commercial CBRS users, they recommended enhancing Spectrum Access System (SAS) coordination through greater automation. This, they argued, should be developed through the existing, successful industry-led cooperative approach, which has already proven effective for TDD synchronization and interference mitigation. Federated Wireless suggested the FCC's role should be to provide guidance and monitor progress, relying on the checks and balances already built into the CBRS multi-stakeholder framework.
Source: [NOTICE OF EXPARTE, Federated Wireless, Inc., https://www.fcc.gov/ecfs/document/1071417259999/1]
ACA Connects - America's Communications Association
Proceeding(s): 17-84, 25-133, 25-59
Date of Meeting: July 10, 2025
Date Disseminated: July 14, 2025
Participants:
ACA Connects - America's Communications Association: Grant Spellmeyer (President & CEO), Brian Hurley (Senior VP of Legal and Regulatory Affairs)
Kelley Drye & Warren LLP: Tom Cohen (Outside Counsel for ACA Connects)
Federal Communications Commission (FCC): Commissioner Olivia Trusty, Jessica Kinsey (Legal Advisor to Commissioner Trusty)
Summary of Discussion:
Representatives from ACA Connects met with Commissioner Olivia Trusty and her Legal Advisor, Jessica Kinsey, to outline the priorities of its approximately 500 small and medium-sized member companies. ACA Connects emphasized their members' significant investments in upgrading and expanding broadband networks, particularly in rural America. They stressed the FCC's critical role in facilitating this growth by removing regulatory obstacles. The discussion covered several key dockets and policy areas:
Delete, Delete, Delete (GN Docket No. 25-133): ACA Connects expressed strong support for the FCC's initiative to eliminate outdated and burdensome regulations. They specifically applauded the recent vote by Commissioner Trusty and the Commission to remove the Broadband Data Collection (BDC) professional engineer certification requirement, a rule they had identified as a top priority for deletion.
Build America Agenda & Pole Attachments (WC Docket No. 17-84): ACA Connects praised Chairman Carr's "Build America Agenda" for its focus on removing deployment barriers. They are particularly encouraged by a draft order scheduled for the July Commission meeting aimed at improving the pole attachment process. Despite past improvements, members continue to face excessive costs, delays, and a lack of transparency when attaching facilities to investor-owned utility poles. They also voiced support for the agenda's plan to re-examine the FCC's authority under Section 253 to streamline local permitting processes, citing challenges with endless reviews and excessive fees that can stall or stop broadband deployment.
State Rate Regulation: ACA Connects raised concerns about increasing efforts by state legislatures to impose price caps or otherwise regulate broadband rates. They cited a recent study they commissioned with the consulting firm Cartesian, which concluded that even modest rate regulation significantly depresses broadband investment. The negative impact is felt most acutely by smaller providers and in rural areas where the business case for expansion is already fragile.
Upper C-Band (GN Docket No. 25-59): ACA Connects explained that its members continue to rely on the Upper C-Band (3.98–4.2 GHz) to receive video programming at their headends. With the FCC mandated to auction a portion of this spectrum, their paramount concerns are ensuring a seamless transition that does not compromise video service quality or reliability, and that members receive full compensation for all reasonable transition-related expenses. They also urged the Commission to provide a sufficient timeline for the complex, multi-stakeholder post-auction transition, warning that the process cannot be rushed despite the two-year auction deadline.
Video Policy: The discussion concluded with the persistent challenges members face in providing affordable cable video service. ACA Connects argued that substantial increases in retransmission consent fees and other onerous terms imposed by programmers are inflating consumer bills and driving cord-cutting. They urged the Commission to avoid regulatory outcomes that would exacerbate these issues and further threaten the viability of video service for many communities.
Source: [NOTICE OF EXPARTE, ACA Connects - America's Communications Association, https://www.fcc.gov/ecfs/document/1071430255854/1]
Intrado Life & Safety, Inc.
Proceeding(s): 07-114
Date of Meeting: July 9, 2025
Date Disseminated: July 15, 2025
Participants: Representatives from Intrado Life & Safety, Inc. (Intrado) held two separate meetings with FCC staff. The Intrado participants in both meetings were:
Brian Davenport, Chief Strategy Officer
John Snapp, Vice President Technology
Lauren Kravetz, Vice President Government Affairs
Charles Gifford, Chief Information Security Officer
They met with:
Meeting 1: Staff from the office of Commissioner Olivia Trusty:
Krista Senell, Chief of Staff and Senior Counsel
William Holloway, Acting Legal Advisor
Meeting 2: Staff from the Public Safety and Homeland Security Bureau (PSHSB):
David Furth
John Evanoff
Brenda Boykin
Rachel Wehr
Rasoul Safavian
Tom Eng
Helen Zhang
Summary of Discussion:
Intrado presented its views on improving 911 location accuracy, focusing on vertical location, dispatchable location, and the legacy requirement to transmit cell site addresses.
1. Measuring and Conveying Vertical Location to the PSAP
Intrado argued that while Height Above Ellipsoid (HAE) is an accurate raw measurement for vertical location, it must be converted into more actionable information for first responders.
Critique of Current Options:
Height Above Ground Level (AGL): Intrado contends that AGL alone is insufficient and can be misleading. It doesn't provide an actionable floor number, especially in buildings with non-standard floor sequencing (e.g., "Courtyard" or "Lobby" levels) or multiple ground-level entrances on different floors.
Detailed Floor Plans: Obtaining detailed floor plans to make AGL useful is extremely difficult, as building owners are not obligated to provide them and are often unwilling to grant access for third-party mapping.
Proposed Solution: Floor-Level Information:
Intrado advocated for converting HAE data into simple floor-level information (e.g., "7th Floor"). This is the most valuable and actionable data for responders ("what button to push in the elevator?") and is more easily and cost-effectively obtained than detailed floor plans.
Intrado recommended that the FCC should require wireless carriers and Multi-line Telephone System (MLTS) providers to survey and share floor-level information for buildings where they maintain infrastructure.
Implementation and Data Management:
To make this data available, it should be stored in a common repository, such as an ESInet map data service or an i3 map data service.
Intrado acknowledged that achieving comprehensive data will be a long-term process. Initial submissions from carriers and MLTS providers would be a "significant downpayment," with future data collection being incorporated into local building and fire codes for new construction and renovations.
In response to a staff question on privacy, Intrado stated that floor-level data mitigates privacy and security concerns more effectively than detailed floor plans.
PSAP Technology and Cost:
Intrado noted that cost-effective options exist for PSAPs. Intrado offers a free HAE-to-AGL conversion upgrade for its NG911 call handling equipment (CHE), and other free, CHE-agnostic mapping solutions are available.
The primary challenge is the software and configuration rollout across the nation's approximately 6,000 PSAPs. Legacy PSAPs pose an additional hurdle, as standards like E2 and ALI would need to be updated to support passing AGL data.
2. Improving Dispatchable Location
Intrado reiterated its support for creating a "personal base map" for callers to improve the chances of establishing a dispatchable location. They argued that wireless carriers could easily leverage existing subscriber information, such as registered Wi-Fi addresses or billing addresses, and transmit this civic location data along with geodetic coordinates to the PSAP. This would provide valuable context to help pinpoint a caller's location.
3. Requirement to Send Cell Site Address
Intrado strongly recommended that the FCC eliminate the requirement for wireless carriers to send cell site location information with a 911 call.
Redundancy: The requirement is obsolete because PSAPs are now capable of processing more precise coordinate-based location data.
Potential for Confusion: Sending cell site addresses, which are not the caller's location, creates a high potential for confusion at the PSAP. A telecommunicator might overlook or discard a true dispatchable address because they are accustomed to receiving non-actionable cell site addresses.
Recommendation: To avoid errors, Intrado argued that the only addresses sent to a PSAP should be those intended to help formulate the caller's actual location.
Source: [NOTICE OF EXPARTE, Intrado Life & Safety, Inc., https://www.fcc.gov/ecfs/document/10714591406497/1]
Zixi, LLC
Proceeding(s): 25-59
Date of Meeting: July 14, 2025
Date Disseminated: July 15, 2025
Participants:
Zixi, LLC: Alan Young, Vice President of Strategic Business Development
Carpenter Strategic Consulting, LLC: Jot Carpenter, Principal
Federal Communications Commission (FCC): Arpan Sura, Office of Chairman Carr
Summary of Discussion:
Representatives from Zixi, LLC, and Carpenter Strategic Consulting, LLC, met with staff from Chairman Carr's office to discuss the Commission's Notice of Inquiry (NOI) regarding the potential reallocation of the Upper C-band spectrum (3.98 GHz to 4.2 GHz). Zixi presented its position that, as the FCC considers repurposing this spectrum, a transition to an IP-focused video delivery model is a logical and timely evolution that can offer quality and reliability advantages over traditional satellite delivery.
The core of the discussion, detailed in a supporting briefing document, focused on solving the reliability gap created by the reduction of C-band spectrum, which has historically served as a crucial redundant delivery path for broadcasters and cable networks. Zixi argued that this is especially critical for rural and edge-market facilities that often have a single terrestrial connection, creating a single point of failure that could disrupt access to emergency information and other programming.
Zixi proposed a solution centered on software-defined multipath redundancy and connection bonding. The key components of their proposed solution are:
Multipath Redundancy and Bonding: Zixi advocates for combining two or more independent IP paths—such as a terrestrial fiber/cable connection bonded with a wireless path like LEO (Low Earth Orbit) satellite, GEO (Geostationary) satellite, or 5G—into a single, highly resilient delivery stream. This creates a fault-tolerant system where if one path experiences issues, video delivery continues uninterrupted over the other(s). They noted that mathematically, combining two paths with 99.9% and 99.95% reliability respectively creates a combined success probability of 99.99995%.
Technology and Standards: The proposed architecture is built on industry standards, using SMPTE 2022-7 for hitless, packet-by-packet switching between paths and Real Time Protocol (RTP) for video payloads, ensuring compatibility with existing broadcast infrastructure.
Zixi Protocol Enhancements: Zixi's proprietary technology further enhances reliability over unmanaged IP networks through a combination of Forward Error Correction (FEC), Automatic Repeat Request (ARQ) for re-transmitting lost packets, null packet compression to reduce bandwidth, and real-time telemetry for monitoring and troubleshooting.
Flexibility and Alignment with FCC Goals: Zixi emphasized that its software-defined platform allows for a tailored configuration at each receive site, intelligently blending whatever connectivity options are available (LEO, GEO, fiber, etc.). They argued this approach aligns with key FCC goals, including ensuring public safety through broadcast continuity, promoting rural inclusion by enabling reliable service where terrestrial options are limited, maintaining competitive neutrality among providers, and increasing technical and spectral efficiency.
In conclusion, Zixi urged the Commission to consider multipath redundancy and bonding-enabled architectures as a viable and superior successor to C-band, particularly for ensuring the resilience of video delivery to rural markets as part of any future transition framework.
Source: [NOTICE OF EXPARTE, Zixi, LLC, https://www.fcc.gov/ecfs/document/1071424657422/1]
Connected Devices for America Coalition
Proceeding(s): 25-110, 24-240, RM-11989
Date of Meeting: July 10, 2025
Date Disseminated: July 15, 2025
Participants:
Meeting with:
Wireless Bureau: Barbara Esbin, Melissa Conway, Linda Chang, Thomas Derenge, Kamran Etemad, Connie Diaz
Office of Engineering and Technology: Ira Keltz, Michael Ha, Jamison Prime
Meeting Participants:
Connected Devices for America Coalition (CDA Coalition): Representatives from a subset of members, including:
Alarm Industry Communications Committee (AICC): John A. Prendergast (Blooston, Mordkofsky, Dickens & Prendergast, LLP), William A. Signer (Carmen Group), Roxanna Fields (Carmen Group)
Johnson Controls, Inc.: Nigel Spinks (on behalf of AICC)
NRG Energy: Jake Braunger (on behalf of AICC)
Digi International Inc.: Sarah Stensland
ecobee, a Generac company: Jena Ginsburg
Itron, Inc.: Ed Eckert, Vicent Paladini, Asim Tirmizi
Landis+Gyr: Marguerite Behringer
Morse Micro: David Halasz, Navod Suraweera
Silicon Labs: Efrén Garcia
Texas Instruments: Hannah Izon, Thomas Almholt
Outside Counsel to the CDA Coalition: C. Sean Spivey, Rachel Wolkowitz, Mark Settle, Kimia Nikseresht (Wilkinson Barker Knauer, LLP)
Summary of Discussion:
Representatives from the Connected Devices for America Coalition (CDA Coalition) met with staff from the WTB and OET to express strong opposition to NextNav Inc.'s petition for rulemaking. The CDA Coalition's members, including Johnson Controls, Itron, Silicon Labs, Texas Instruments, and others, are significant innovators and users of the 902-928 MHz band ("Lower 900 MHz Band") for a wide array of critical services.
The Coalition's main arguments are summarized below:
Support for PNT Resiliency, Opposition to NextNav's Method: While the Coalition supports the FCC's goal of enhancing Positioning, Navigation, and Timing (PNT) resiliency as an alternative to GPS, it argued that any solution must not harm the vibrant, existing ecosystem in the Lower 900 MHz Band. They contend that NextNav's proposal to reconfigure the band for a high-power 5G/PNT service would upend a successful regulatory framework for the enrichment of a single company.
Catastrophic Impact on Incumbent Users: The Coalition detailed the extensive and critical use of the band by incumbent Part 15 unlicensed devices. They argued NextNav's plan would cause catastrophic failures and interference for:
National Security and Public Safety: Degrading military and law enforcement RFID asset tracking, alarm signaling (fire, medical, burglary), gunshot detection, and emergency vehicle systems like traffic light preemption.
Critical Infrastructure: Disrupting utility meters, remote shutdown systems for oil and gas wells, and industrial sensors.
Consumers and Commerce: Rendering inoperable millions of consumer smart home devices (thermostats, locks), industrial automation systems, and electronic tolling transponders, which would require massive and costly replacement efforts. The Coalition cited a study by former FCC Commissioner Harold Furchtgott-Roth estimating the economic cost of NextNav's proposal would be in the "tens of billions of dollars."
Fundamental Alteration of Band Rules: The Coalition argued that NextNav seeks to fundamentally change the band's rules to its benefit. This includes eliminating the current requirement for NextNav to conduct field tests to prove it won't cause unacceptable interference and removing the "safe harbor" that protects unlicensed devices. This would effectively compress the hundreds of millions of existing devices into roughly 40% of the band or force them out entirely.
Critique of NextNav's Technical Analysis: The Coalition asserted that NextNav's technical study, which claims its 5G network can coexist with Part 15 devices, is fundamentally flawed and cannot be relied upon. The key flaws identified include:
Misunderstanding of Incumbent Use: The analysis fails to grasp how Part 15 devices actually use the band and ignores the impact of removing key interference protections.
Unrealistic Assumptions: NextNav used a 20% base station loading factor, which is inconsistent with ITU and FCC standards that suggest 50%. It also modeled fewer base stations in San Francisco than are actually deployed for existing sub-1 GHz services, underpredicting interference by a factor of up to 10.
Incorrect Modeling: The study overestimates Part 15 device activity, ignores adjacent-channel interference from 5G, over-relies on frequency hopping as a mitigation technique, and uses an overly generous assumption for building entry loss.
Incomplete Analysis: NextNav only examined half of the interference scenario (downlink) and ignored the impact of 5G uplink operations on Part 15 devices.
In conclusion, the CDA Coalition urged the FCC to reject NextNav's petition. They argued that NextNav has not met its burden to prove the rule changes are in the public interest and has failed to demonstrate that its proposal would not cause unacceptable interference to the deeply embedded and critical services already operating in the Lower 900 MHz Band.
Source: [NOTICE OF EXPARTE, Connected Devices for America Coalition, https://www.fcc.gov/ecfs/document/1071448718592/1; https://www.fcc.gov/ecfs/document/1071448718592/1; https://www.fcc.gov/ecfs/document/1071448718592/2]
Pearl TV
Proceeding(s): 16-142
Date of Meeting: July 10, 2025
Date Disseminated: July 15, 2025
Participants:
Pearl TV: Anne Schelle (Managing Director)
Covington & Burling LLP (Counsel for Pearl TV): Gerard J. Waldron
Media Bureau: Erin Boone, Maria Mullarkey, Evan Morris, Evan Baranoff, Mark Colombo, Lyle Elder
Summary of Discussion:
Representatives from Pearl TV, a coalition of major broadcast groups including Cox Media Group, Gray Media, Hearst Television, Nexstar Media Group, Inc., and others, met with Media Bureau staff to advocate for Commission action to finalize the transition to the ATSC 3.0 (NEXTGEN TV) broadcast standard. The central request was for the FCC to promptly issue a Notice of Proposed Rulemaking (NPRM), based on a petition from the National Association of Broadcasters (NAB), to establish a firm sunset date for the legacy ATSC 1.0 standard.
Pearl TV argued that a set transition date is critical to provide the regulatory certainty needed for the entire broadcast ecosystem—including consumer electronics (CE) manufacturers, converter box developers, retailers, and smaller market broadcasters—to commit to the final stage of the transition.
Key points and data presented in support of their position include:
Significant Progress and Investment: The broadcast industry has successfully driven the voluntary transition to cover 76% of U.S. households (96 million) across 73 of the top 100 TV markets. A cumulative total of 15 million NEXTGEN TV-capable televisions have been sold, with CTA forecasting another 5 million by the end of 2025. Broadcasters have deployed over 600 NEXTGEN TV services, offering viewers enhanced features like High Dynamic Range (HDR) color, Dolby Atmos audio, and interactive capabilities like "program re-start."
Development Stalled by Uncertainty: Despite this progress, Pearl TV stressed that the lack of a firm sunset date is hindering further investment and development. They highlighted that the development cycle for new receivers and set-top boxes is at least 18 months. Without a clear signal from the FCC, manufacturers are adopting a "wait-and-see" approach. This delay jeopardizes the availability of affordable converter boxes, as substantial investments needed to trigger mass production are being withheld. Pearl TV warned that each quarter of inaction risks pushing the timeline back by another full year due to seasonal retail and manufacturing schedules.
Consumer Demand and Benefits: Pearl TV presented evidence of strong consumer interest, noting that the top inquiry on their consumer-facing website, WatchNextGenTV.com, is from consumers asking why certain TV brands lack ATSC 3.0 receivers. They also noted that one of the most important public interest benefits of a completed transition is the ability to deliver enhanced and customized emergency information, such as localized evacuation routes and flood maps, which is not possible with the current standard.
Rebuttal to Opposition: Pearl TV addressed opposition from other industry groups. They dismissed claims from the American Television Alliance that the FCC lacks the authority to sunset a rule, pointing to recent deregulatory precedents. They also accused the NCTA and certain members of the Consumer Technology Association (CTA) of acting out of anti-competitive motives. Pearl TV argued that some TV manufacturers now compete directly with broadcasters for viewers and advertising dollars through their own Free Ad-Supported Streaming Television (FAST) channels, giving them an incentive to "stifle broadcast innovation."
In conclusion, Pearl TV urged the Media Bureau and the Commission to act swiftly on the NAB's petition. They argued that an NPRM signaling the Commission's intent to set a transition date is the necessary catalyst to unlock final investments, accelerate the development of affordable devices, and ensure that all consumers can access the benefits of NEXTGEN TV.
Source: [NOTICE OF EXPARTE, Pearl TV, https://www.fcc.gov/ecfs/document/107150777700259/1]
CTIA
Proceeding(s): 25-70, 25-71, 25-117, 13-185
Date of Meeting: July 15, 2025
Date Disseminated: July 15, 2025
Participants: This ex parte communication was a written letter submitted by Sarah Leggin (Vice President, Regulatory Affairs, CTIA)
Summary of Discussion:
In a written ex parte filing, CTIA expressed strong support for the FCC Draft Order concerning the rules for the upcoming auction of AWS-3 spectrum inventory (Auction 113). CTIA urged the FCC to quickly adopt the final procedures to advance U.S. leadership in wireless, bolster the economy, and enhance national security.
The primary arguments presented by CTIA include:
Alignment with Congressional and Administration Goals: The auction is a critical step in fulfilling the mandate of the Spectrum and Secure Technology and Innovation Act (SSTIA) to make more spectrum available for consumer use.
National Security: CTIA highlighted that proceeds from Auction 113 are designated to support the FCC's Supply Chain Reimbursement Program. This program is essential for protecting American networks by funding the removal of "untrustworthy and insecure foreign equipment."
Rejection of a Tribal Licensing Window: CTIA strongly endorsed the Draft Order's conclusion to forgo a Tribal licensing window for the AWS-3 spectrum. CTIA argued that such a window would be contrary to the public interest for several reasons cited in the Draft Order:
It would "further delay" the deployment of AWS-3 spectrum.
It could "potentially reduce the auction proceeds" necessary to fund the Supply Chain Reimbursement Program.
A simultaneous Tribal window and auction would not provide bidders sufficient time to "develop business plans" or "assess market conditions," as required by the Communications Act.
Call to Action: CTIA explicitly requested that the FCC reject calls from other organizations, such as Public Knowledge and the Coalition of Large Tribes, to deviate from the Draft Order's findings. CTIA stressed the importance of moving forward to secure U.S. networks and make more full-power commercial spectrum available to meet growing consumer demand.
Source: [NOTICE OF EXPARTE, CTIA, https://www.fcc.gov/ecfs/document/1071565181120/1]
Enterprise Wireless Alliance
Proceeding(s): RM-11979
Date of Meeting: This ex parte filing is a written submission, not a record of a meeting. The comments are dated July 14, 2025, and the cover letter is dated July 15, 2025.
Date Disseminated: July 15, 2025
Participants:
Filer: Enterprise Wireless Alliance (EWA), represented by Robin J. Cohen (President/CEO) and Elizabeth R. Sachs (Counsel, Lukas, LaFuria, Lantor & Sachs, LLP).
Comments were directed to the Chief of the Public Safety and Homeland Security Bureau.
Summary of Discussion:
The Enterprise Wireless Alliance (EWA) filed written comments to express its support for a waiver request from the County of Aroostook, Maine (Aroostook). The waiver, under consideration in DA 25-551, would allow Aroostook to license an Industrial/Business (I/B) Pool channel for its fifteen-site VHF public safety communications system.
EWA's support is based on the principle of allowing the use of otherwise fallow spectrum when an applicant's needs cannot be met by spectrum specifically allocated for their use. Aroostook is seeking to replace an end-of-life system and has been unable to find available Public Safety (PS) spectrum for over two years. This search was complicated by the county's large geographic area and its location in northern Maine, which requires Canadian concurrence for VHF frequencies. The waiver request is supported by a certification from APCO confirming that no suitable PS VHF frequencies are available.
The I/B frequency identified by Aroostook is designated for LA (automobile emergency service), and the application includes consent letters from AAA, the primary frequency coordinator for these channels. EWA notes that the letters were signed by Francine Cook, an employee of RadioSoft, which is not an FCC-certified Frequency Advisory Committee, but assumes the FCC has approved this arrangement with AAA.
EWA leverages this specific waiver request to advocate for its broader rulemaking petition, RM-11979. EWA argues that the availability of this LA channel for public safety use demonstrates that the special coordination procedures required for certain I/B frequencies under Rule Sections 90.35(b)(1)-(3) no longer serve the public interest. EWA contends that these special protections lead to underutilization of spectrum while adding unnecessary cost and delays to the coordination process. Consequently, EWA strongly urges the FCC to grant Aroostook's waiver and to move forward with EWA's Petition for Rulemaking (RM-11979) to eliminate these outdated procedures.
Source: [NOTICE OF EXPARTE, Enterprise Wireless Alliance, https://www.fcc.gov/ecfs/document/10715113355488/1]
Foreign Investment Review Section (FIRS), National Security Division (NSD) at the U.S. Department of Justice (DOJ), on behalf of the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (Committee or Team Telecom). Committee member agencies (DOJ, U.S. Department of Homeland Security, and the U.S. Department of Defense)
Proceeding(s): OI Docket No. 24-523, MD Docket No. 24-524
Date of Meeting: The letter, dated July 14, 2025, serves as an ex parte communication following up on prior staff-level meetings referenced in filings from May 23, 2025, and June 2, 2025.
Date Disseminated: July 14, 2025
Participants: The letter was submitted by Devin A. DeBacker, Chief of the Foreign Investment Review Section (FIRS), National Security Division (NSD) at the U.S. Department of Justice (DOJ), on behalf of the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (Committee or Team Telecom). The prior meetings involved representatives from Committee member agencies (DOJ, U.S. Department of Homeland Security, and the U.S. Department of Defense) and staff from the Federal Communications Commission (FCC).
Summary of Discussion:
The Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (Committee) submitted a letter to the FCC to emphasize the importance of protecting U.S. submarine cable systems from foreign adversary threats and to expand on its previously filed comments in the proceeding Review of Submarine Cable Landing License Rules and Procedures to Assess Evolving National Security, Law Enforcement, Foreign Policy, and Trade Policy Risks.
The key arguments presented by the Committee include:
Definition of a Submarine Cable System: The Committee strongly advocates for the definition of a "submarine cable system" to include Submarine Line Terminal Equipment (SLTE). It argues that owning or operating SLTE is functionally equivalent to operating a cable without a license, as it allows an entity to route its own traffic. The Committee notes that it already reviews SLTE providers and installers for national security risks as part of its standard process.
National Security Risks of SLTE and Dark Fiber: The Committee highlighted the significant risks posed by foreign adversary-affiliated entities owning or operating SLTE, particularly through Indefeasible Rights of Use (IRUs) for dark fiber. Such arrangements could allow an adversary to bypass licensing and regulatory review, creating opportunities to intercept or misroute U.S. communications. The Committee cited its recommendation to deny the ARCOS-1 cable expansion to Cuba as an example of this threat.
To mitigate this, the Committee supports its previous recommendation that the FCC require licensees to report information about non-licensee entities that own or operate their own SLTE.
Regarding the FCC's proposal to outright prohibit dark fiber IRU agreements with foreign adversaries, the Committee stated it does not oppose this "bright line rule," as it would enhance regulatory certainty, even if robust reporting requirements might offer an alternative solution.
Closing Regulatory Loopholes: The Committee reiterated its support for rules that would presume denial for applicants previously denied or revoked on national security grounds. It also supports prohibiting or presuming denial for applications to land cables in foreign adversary countries.
Supply Chain Integrity: The Committee supports the FCC’s proposal to require licensees to certify whether they use equipment from the "Covered List" and believes that requiring the removal of such equipment is necessary. It also urged the FCC to look beyond the "Covered List" and use other government sources, like the Department of Commerce's Entity List, to identify threats.
The Committee proposed an even broader approach: requiring licensees to certify they will not use vendors who meet the definition of a person "owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary," citing existing definitions from the Department of Commerce and Department of Justice. This flexible, non-list-based approach would better address evolving threats, though the Committee acknowledged that waivers might be needed for circumstances like emergency repairs.
Source: [NOTICE OF EXPARTE, Jessica L. Campbell, https://www.fcc.gov/ecfs/document/107152796823736/1]
Hispanic Leadership Fund
Proceeding(s): 15-91, 15-94
Date of Meeting: July 15, 2025
Date Disseminated: July 15, 2025
Participants: A letter was sent from Mario H. Lopez, President of the Hispanic Leadership Fund (HLF), to Brendan Carr, Chairman of the FCC.
Summary of Discussion:
In a letter, the Hispanic Leadership Fund (HLF) expressed its position on the implementation of multilingual Wireless Emergency Alerts (WEAs). The HLF supports the FCC's overall goal of ensuring emergency alerts are accessible to individuals whose primary language is not English, noting the significant value that Spanish-language WEAs have provided to the Latino community.
However, the HLF raised significant concerns about the FCC's proposal to use predefined, multilingual WEA templates. The primary argument is that such templates may be too rigid and inflexible for the dynamic nature of emergencies. The HLF contends that local emergency officials require the ability to craft customized messages that are sensitive to local culture and can be adapted to rapidly changing situations like floods, wildfires, or tornados.
Instead of relying solely on generic templates, the HLF urged the FCC to consider and promote more flexible and technologically advanced solutions. The organization suggested two key alternatives:
Utilizing Web Links: WEAs could include links to websites where local officials can provide detailed, up-to-the-minute emergency information in multiple languages and formats.
Leveraging New Technologies: The HLF highlighted the potential of Artificial Intelligence (AI) and machine language translation to empower officials to quickly generate customized, targeted messages in numerous languages, offering a more effective solution than inflexible templates.
The HLF warned that deploying templates that local officials are unlikely to use could be "counterproductive" and create "unintended consequences," ultimately harming public safety. The letter concludes by urging the Commission to carefully evaluate all options to find the most efficient and accurate solution for delivering critical, life-saving information to non-English speaking communities.
Source: [NOTICE OF EXPARTE, Hispanic Leadership Fund, https://www.fcc.gov/ecfs/document/10715088326106/1]