The Daily Ex Parte, July 7, 2025
Opposition to USCellular/T-Mobile/AT&T/Verizon Transactions, PNT/E911, & "national security loopholes in its Equipment Authorization Program."
The Daily Ex Parte
Filers
Rural Wireless Association, Inc., Communications Workers of America, Public Knowledge, New America's Open Technology Institute —25-150, 24-286, 25-192
oneNav, Inc. — 25-110, 07-114
Jiwon Ma — 21-232, 21-233
Rural Wireless Association, Inc., Communications Workers of America, Public Knowledge, New America's Open Technology Institute
Proceeding(s): 25-150, 24-286, 25-192
Date of Meeting: July 01, 2025
Date Disseminated: July 07, 2025
Participants:
Coalition Attendees:
Carri Bennet and Stephen Sharbaugh (Rural Wireless Association, Inc.)
Hooman Hedayati (Communications Workers of America)
Peter Gregory (Public Knowledge)
Michael Calabrese (New America's Open Technology Institute)
FCC Staff:
Arpan Sura, Senior Counsel and Chief AI Officer to Chairman Brendan Carr
Deena Shetler, Chief of Staff and Legal Advisor to Commissioner Anna Gomez
Edyael Casaperalta, Legal Advisor to Commissioner Anna Gomez
Summary of Discussion:
The coalition of RWA, CWA, PK, and New America met with FCC staff to discuss the proposed transactions involving United States Cellular Corporation ("USCellular") and its sale of assets to New Cingular Wireless PCS, LLC ("AT&T"), T-Mobile US, Inc. ("T-Mobile"), and Cellco Partnership ("Verizon"). The central argument presented was that these three transactions, which effectively represent UScellular's exit from the mobile wireless market, are interdependent and must be reviewed together as a whole, rather than as separate, isolated deals. The coalition argued that a piecemeal review would obscure the cumulative competitive harms and prevent a meaningful public interest analysis.
Key points raised by each organization include:
Rural Wireless Association, Inc. (RWA) expressed significant concern over the elimination of UScellular as a facilities-based competitor in rural markets and a reliable roaming partner. RWA argued:
The transactions will concentrate valuable low- and mid-band spectrum in the hands of the three largest national carriers, with rural carriers having had no meaningful opportunity to acquire it. RWA noted that UScellular's initial announcement about exploring "strategic alternatives" was too vague to signal that its spectrum was for sale.
UScellular has historically offered commercially reasonable, reciprocal roaming agreements to rural carriers. Its replacement by AT&T could lead to unilateral, more expensive roaming agreements, threatening the viability of rural networks and their ability to provide public safety communications.
The elimination of UScellular as a competitor will inevitably lead to higher consumer prices, pointing to recent rate increases by both T-Mobile and AT&T after previous market consolidation.
RWA called for the FCC to direct the Universal Service Administrative Company ("USAC") to audit UScellular's use of its approximately $100 million in annual legacy mobile high-cost support. Given recent employee layoffs and notices to relinquish its Eligible Telecommunications Carrier (ETC) status, RWA questioned whether these funds, required to be spent on 5G, were used appropriately and suggested the FCC consider clawing back any misused support.
Public Knowledge (PK) focused on the applicants' burden of proof. PK stated that the applicants have failed to demonstrate that the transaction serves the public interest or that it will result in no consumer harm. PK argued there is insufficient evidence of transaction-specific benefits and reiterated the need to analyze the aggregate effects of all three UScellular sales. If the transaction were to be approved, PK suggested that pro-competitive conditions, such as a device unlocking requirement, would be necessary.
New America's Open Technology Institute (New America) strongly advocated for handset unlocking requirements to promote consumer choice. New America noted that countries like Canada and the United Kingdom have successfully implemented point-of-sale unlocking mandates without experiencing significant increases in fraud. They said that Verizon's recent request for a waiver of its own unlocking rules underscores the need for the FCC to finalize its pending industry-wide unlocking rulemaking. In the interim, New America urged the FCC to impose transaction-specific handset unlocking conditions, consistent with the precedent set in the T-Mobile-Mint Mobile order.
Communications Workers of America (CWA) raised concerns about the impact on the labor market. CWA argued that the transactions, particularly the T-Mobile/UScellular deal, will further entrench T-Mobile's dominance in local labor markets for retail wireless workers. CWA stated that the applicants have not met their burden to show how the deals will enhance competition in either labor markets or downstream consumer markets.
Source: [NOTICE OF EXPARTE, Rural Wireless Association, Inc., Communications Workers of America, Public Knowledge, New America's Open Technology Institute, https://docket-rocket.io/filings/10703853027666]
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These are the recent filings on 25-110 with the oneNav row expanded to view the Detailed Summary and Source Document hyperlinks:
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oneNav, Inc.
Proceeding(s): 25-110, 07-114
Date of Meeting: July 1, 2025
Date Disseminated: July 07, 2025
Participants:
From oneNav, Inc.:
Steven Poizner, Co-Founder and Chief Executive Officer
Dr. Paul McBurney, Co-founder and Chief Technology Officer
Tim McCarthy, GNSS Product Lead
J.G. Harrington, Counsel (Cooley)
Robert M. McDowell, Counsel (Cooley)
From the FCC:
Office of Engineering and Technology:
Ira Keltz, Acting Chief Engineer
Michael Ha, Chief, Policy & Rules Division
Public Safety and Homeland Security Bureau:
Zenji Nakasawa, Acting Bureau Chief
Jim Schlichting, Senior Deputy Bureau Chief
David Furth, Deputy Bureau Chief
Kenneth Carlberg, Chief Technology Officer
John Evanoff, Chief, Policy & Licensing Division
Brenda Boykin, Deputy Chief, Policy & Licensing Division
Rasoul Safavian
Wireless Bureau:
Joel Taubenblatt, Acting Bureau Chief
Barbara Esbin, Deputy Bureau Chief
Linda Chang, Associate Chief, Mobility Division
David Hu
Summary of Discussion:
Representatives from oneNav, Inc. presented their views on improving location accuracy and resiliency for E911 services, focusing on the benefits of the modernized L5 GNSS signal. The discussion centered on the limitations of the legacy L1 signal and the advantages of their "L5-direct" technology.
oneNav made three key policy recommendations to the FCC:
Tighten E911 Accuracy: Require horizontal (x-y) E911 location information to meet an accuracy standard of 20 meters at a 68% confidence level.
Mandate "Independent L5": Require the use of "Independent L5" fixes for GNSS-based location services used in 911 calls to improve resilience against jamming and spoofing.
Advocate for L5 Operational Status: Urge the U.S. Space Force to grant full operational status to the U.S. GPS L5 constellation in 2025, noting that the U.S. lags behind China and the EU.
Arguments and Supporting Points:
Legacy L1 Signal is Obsolete: oneNav argued that the L1C/A signal, developed in the 1970s, is outdated and highly susceptible to multipath interference, jamming, and spoofing. Most current dual-band receivers create a critical vulnerability by requiring a successful L1 signal acquisition before they can track the more modern L5 signal. This dependency means that if the L1 signal is jammed or unavailable, the receiver cannot utilize the superior L5 signal.
Superiority of the L5-Band Signal: The L5 band offers significant advantages, including operation in a protected spectrum, 2x higher power, 10x wider bandwidth, and 10x longer spreading codes. These features result in higher accuracy, better noise rejection, and a 600-700% smaller jamming radius compared to L1. There are already over 70 L5-capable satellites in orbit across multiple constellations (GPS, Galileo, BeiDou).
oneNav's "L5-direct" Technology: oneNav presented its proprietary technology, which enables GNSS receivers to acquire L5 signals directly without depending on the L1 signal. This "Independent L5" capability makes their solution immune to L1 jamming and highly resilient to in-band interference and spoofing.
Performance Data: oneNav shared test data from dense urban environments in San Francisco, demonstrating that its L5-direct receiver consistently outperformed leading L1/L5 dual-band receivers in accuracy, yield, and Time To First Fix (TTFF). Their tests showed that with access to all L5 constellations, their receiver can achieve accuracy below 20 meters at 68% confidence (CEP68), meeting their proposed E911 standard.
Validation: The company cited successful validation and testing with various U.S. government entities, including the Navy, Army, and Special Forces, which confirmed the system's resilience to jamming and spoofing. They also noted active development programs with In-Q-Tel and commercial validation from companies like Google and Meta for use in wearables and for coexistence with other services.
In conclusion, oneNav argued that adopting their recommendations would leverage modern, available technology to provide a meaningful improvement in public safety by ensuring more accurate and resilient location data for E911 calls, particularly in challenging urban and contested environments.
Source: [NOTICE OF EXPARTE, oneNav, Inc., https://docket-rocket.io/filings/107033071820533]
Jiwon Ma
Proceeding(s): 21-232, 21-233
Date of Meeting: This is a written Ex Parte submission dated July 7, 2025.
Date Disseminated: July 07, 2025
Participants: A written presentation was submitted by Jiwon Ma, Senior Policy Analyst at the Foundation for Defense of Democracies (FDD), to the Federal Communications Commission (FCC).
Summary of Discussion:
In a detailed written submission, Jiwon Ma of the Foundation for Defense of Democracies (FDD) argues that the FCC must take further action to close significant national security loopholes in its Equipment Authorization Program. The filing highlights that while the FCC's November 2022 rules prohibiting new authorizations for equipment from Covered List entities like Huawei, ZTE, and Hikvision were a positive step, critical vulnerabilities remain.
The core arguments and recommendations presented are:
1. The "Grandfathering" Loophole and Need for Revocation Authority:
A major regulatory gap exists because equipment from Covered List vendors that received authorization before the February 6, 2023, ban remains legal to be sold, deployed, and operated indefinitely.
This previously authorized equipment poses identical security risks as newly banned devices, as it can still receive firmware updates and transmit data to manufacturers. The filing cites warnings from former Commissioner Nathan Simington and Chairman Brendan Carr about the continued presence and threat of this equipment.
The FDD asserts that the FCC's current authority to revoke authorizations under §2.939 is insufficient, as it is primarily for technical non-compliance or misrepresentation, not for national security risks that arise when a vendor is added to the Covered List.
2. Ambiguous Definitions that Enable Supply Chain Infiltration:
The definition of equipment "produced by" a covered entity is too narrow. This allows adversaries to supply critical components for devices that are ultimately assembled and branded by seemingly legitimate, non-covered firms. These components can introduce the same vulnerabilities.
Complex ownership structures and investment schemes are used to obscure connections to foreign adversaries.
Recommendations:
To address these vulnerabilities, the FDD proposes a three-pronged approach:
Harmonize Security Standards and Establish a Revocation Framework: The FCC should be granted clear authority to revoke existing equipment authorizations for devices from vendors on the Covered List. This should be implemented through a risk-based framework developed with industry, which would prioritize replacing the most sensitive equipment first to minimize the burden on operators, especially in rural areas. The FDD calls for an emergency rulemaking process to be completed within six months.
Strengthen Supply Chain Transparency for Components: The FCC should expand its definition of equipment "produced by" a covered entity to include devices containing critical components that are produced, designed, or manufactured by a Covered List entity. The filing strongly recommends adopting the Department of Commerce's comprehensive definition of foreign adversary control found in 15 CFR § 791.2, which better accounts for complex ownership, agency relationships, and other forms of control.
Expand Information Collection on Foreign Adversary Connections: Building on the FCC's recent move to lower foreign ownership disclosure thresholds for test labs, manufacturers and importers should also be held to higher disclosure standards. This includes reporting material business partnerships with foreign entities, even those not on the Covered List, to allow the FCC to proactively identify and mitigate potential supply chain risks.
The filing concludes that without these reforms, adversaries will continue to exploit regulatory loopholes, undermining U.S. national security.
Source: [NOTICE OF EXPARTE, Jiwon Ma, https://docket-rocket.io/filings/10707008906659]