Danielle Frappier

Danielle Frappier

Davis Wright Tremaine LLP

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FCC Proposes Fine for Alleged Violation of E-rate Lowest Corresponding Price Rule

On July 27, the FCC proposed a penalty of $106,425 against AT&T for allegedly violating its “lowest corresponding price” (“LCP”) rule, which requires that E-rate service providers offer their services to participating schools...more

8/3/2016 - AT&T E-Rates FCC Notice of Apparent Liability (NAL) School Districts

ETCs and State Commissions Seek to Overturn Some of the New FCC Lifeline Rules

As was expected after the FCC’s sweeping Lifeline rule changes, several parties filed Petitions for Reconsideration of the controversial Lifeline Modernization Order. Petitioners, consisting of trade associations, ETCs, and...more

7/7/2016 - ETCs FCC Lifeline Program Mobile Broadband Services

New FCC Lifeline Rules: Effective Dates Clarified Multiple Times But Some Discrepancies Remain

The Lifeline Modernization Order was published in the Federal Register on May 24, making the effective date of the Order June 23, 2016. Most of the rule changes, however, cannot take effect until the Office of Management and...more

6/29/2016 - Broadband FCC Lifeline Program OMB

The Lifeline Modernization Order

Last week, the FCC finally released the full, 224-page text of its controversial and anxiously awaited Lifeline Modernization Order, which was approved by a bitterly divided, party-line 3-2 vote on March 31. As we advised in...more

5/6/2016 - Broadband Cell Phones FCC Lifeline Program Mobile Broadband Services Mobile Devices Telecommunications Wi-Fi Hotspot

Commissioners Wheeler and Clyburn Unveil Aspects of Major Lifeline Overhaul

On March 8, 2016, FCC Chairman Tom Wheeler and Commissioner Mignon Clyburn unveiled a fact sheet summarizing their plan to “re-orient” the Lifeline program towards broadband service and a recap of the existing reforms...more

3/11/2016 - FCC Lifeline Program Mobile Broadband Services Telecommunications

New Lifeline Rules to Become Effective Beginning February 4

Last summer, the FCC adopted new rules for the Lifeline program in its Second Order and NPRM (see our prior analysis of the order), including: the retention of eligibility documentation (such as scans of food stamp cards); an...more

2/3/2016 - ETCs FCC Lifeline Program NPRM OMB

Second Chance to File Oppositions to CTIA Challenge

In its June 2015 Lifeline Order on Reconsideration, the FCC adopted a new rule which requires ETCs to retain documentation demonstrating subscriber eligibility for Lifeline, such as a copy of the applicant’s food stamp card...more

10/7/2015 - Compliance Customer Proprietary Network Information (CPNI) Data Collection ETCs FCC Lifeline Program Personally Identifiable Information Privacy Laws Telecommunications Wireless Industry Wireless Technology

FCC Adopts New Rules, Proposes Further Reforms for Lifeline Program

Last week, the FCC released its second major order in the Lifeline reform proceeding: Second Further Notice of Proposed Rulemaking, Order on Reconsideration, Second Report and Order, and Memorandum Opinion and Order...more

6/30/2015 - Broadband ETCs FCC Lifeline Program OMB Telecommunications Tribal Lands

Staff Releases Lifeline Broadband Pilot Report as FCC Gears Up for Vote on Lifeline Support for Broadband

Last Friday, staff in the FCC’s Wireline Competition Bureau issued a report summarizing the results of the FCC’s Lifeline broadband pilot program. The program was designed to determine how the Lifeline program might address...more

5/29/2015 - Broadband ETCs FCC Lifeline Program Mobile Broadband Services Telecommunications

Categories 1 and 2 to be Fully Funded for 2015-2016 Funding Year

For the first time in many years, the FCC has announced that it anticipates being able to fund all E-rate funding requests. Last Friday, the FCC issued a Public Notice that states that the estimated demand for Category 1...more

5/12/2015 - E-Rates FCC Federal Funding Telecommunications

FCC Likely to Launch New Rulemaking Proceeding to Further Reform Lifeline Program

The FCC is gearing up to launch a new rulemaking proceeding to once again overhaul the Lifeline program. The last major reform of the program was in 2012, and this new rulemaking would likely continue the work of some of the...more

4/25/2015 - Broadband Cell Phones FCC Internet Lifeline Program Pew Foundation Popular

TracFone Files Supplement to Emergency Petition for FCC Preemption on 911 Fees

As noted in our prior update, in November 2014, the FCC Wireline Competition Bureau issued a Public Notice requesting industry comment on a Petition filed by TracFone Wireless regarding 911 fees charged to Lifeline...more

4/13/2015 - FCC Preemption September 11th Attacks TracFone Wireless Utility Fees Wireless Industry

E-rate Funding Year 2015 Filing Window Extended until April 16, 2015

Late last week, USAC announced an extension of the application deadline for Funding Year 2015 (July 1, 2015-June 30, 2015). FCC Form 471 applications must be submitted on or before 11:59:59 pm EDT on Thursday, April 16, 2015....more

4/13/2015 - Applications E-Rates FCC Filing Deadlines Time Extensions USAC

FCC Forbears “For Now” From Requiring Universal Service Contribution From Broadband Providers

Section 254(d) of the Act requires providers of “telecommunications services” to contribute to the federal Universal Service Fund (USF), which is used to subsidize telephone and broadband service in high-cost areas, for...more

3/18/2015 - Bias Broadband FCC Telecommunications

FCC Votes to Approve New Net Neutrality Rules

On a party-line 3-2 vote, the FCC on February 26, 2015, approved new Open Internet (or Net Neutrality) rules, although it has not released the text of its actual ruling. Based on an FCC press release and a written statement...more

3/2/2015 - FCC Final Rules Internet Net Neutrality Telecommunications Act

New FCC Order Increases E-rate Program by $1.5 Billion Annually, and Introduces a Number of New Changes Including “Equalizing”...

On December 19, the FCC released the text of its Second Report and Order in its E-rate modernization proceeding. The new Order increased the annual spending cap on the E-rate program by an additional $1.5 billion—taking the...more

1/2/2015 - Broadband E-Rates FCC Funding Rulemaking Process Wifi

FCC Releases Text of Wi-Fi-Focused E-Rate Reform Order and Further NPRM

Last Thursday, July 24, the FCC issued the 176-page text of its E-rate Modernization Order (“Order”), which it adopted on July 11 in a sharply divided and partisan 3-2 vote. The Order includes a Further Notice of Proposed...more

7/30/2014 - Broadband E-Rates FCC Funding Rulemaking Process Wifi

Chairman Wheeler Urges Prioritizing E-Rate Funding for Wi-Fi by Next Year

FCC Chairman Wheeler posted a blog entry today on the agency’s website emphasizing the need to change its E-rate rules before the next e-rate funding year in order to encourage the deployment of Wi-Fi to the nation’s schools...more

6/20/2014 - E-Rates FCC Internet Wireless Technology

FCC Rescinds 2010 Cost Allocation Guidance for Bundled Services

Late last Friday, the FCC’s Wireline Competition Bureau released an Order rescinding prior guidance that permitted E-rate applicants to request full funding for certain bundles that included service or equipment components...more

6/6/2014 - Bundling Rules E-Rates FCC Telecommunications

New Federal Poverty Guidelines for 2014 Released

The Department of Health and Human Services released its annual update of the federal poverty guidelines (“FPG”) for 2014. This updates the income levels used to qualify applicants for Lifeline-supported service, although...more

2/27/2014 - Federal Poverty Line HHS Poverty

FCC Initiates Massive E-Rate Program Overhaul

On July 23, 2013, the Federal Communications Commission (FCC) released the 175-page text of a Notice of Proposed Rulemaking to transform the Schools and Libraries component of its Universal Service program—more commonly known...more

7/30/2013 - E-Rates FCC Internet Proposed Regulation Telecommunications Act

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