Robocalling Rules

Keller and Heckman Partner Tracy Marshall authored an article featured in Law360 earlier this month discussing the implications of the FCC’s recent declaratory ruling on the treatment of “robocalls” by energy utilities (Vol. XIII, Issue 32). The Telephone Consumer Protection Act of 1991 (TCPA) generally prohibits calls and texts placed using an automatic telephone dialing system or a prerecorded or artificial voice absent consent or an “emergency purpose.” The FCC’s recent ruling confirms that utility companies are deemed to have consent to place robocalls to numbers provided by their customers on matters closely related to the utility services, but utilities must still comply with other TCPA requirements. For more information, please contact Tracy Marshall (; 202.434.4234).

Connecticut Pole Attachment Dispute

The Connecticut Public Utilities Regulatory Authority (PURA) will hold a technical hearing on Oct. 27 to resolve a pole attachment dispute. PURA held a meeting earlier this year to attempt to resolve pole attachment concerns related to the United Illuminating Company (UI) (Vol XIII, Issue 21). To this point, mediation has not been successful, as UI and third party attachers have been unable to resolve issues related to over-lashing. For more information, please contact Tom Magee (; 202.434.4128).

Lower Pole Attachment Rates?

TRDaily reported that the wireless legal adviser to FCC Commissioner Pai informed the CTIA wireless association conference in Las Vegas last week that the Commissioner believes the FCC should focus on things “that will make a difference” to wireless deployment, such as lower pole attachment rates. For more information, please contact Tom Magee (; 202.434.4128).

Ligado Business Plan

Ligado Network LLC’s (formerly LightSquared) has updated its business plan for its proposed advanced satellite-terrestrial network to serve the Internet of Things (IoT) in the rail, trucking, aviation, public safety, and oil and gas sectors. Ligado expects to deploy 10,000 to 20,000 base stations to support its proposed network. The public comment period recently closed for Ligado’s proposal, which among other things requests the FCC allocate the 1675-1680 MHz band for terrestrial mobile use shared with the federal government (Vol. XIII, Issue 30). For more information, please contact Doug Jarrett (; 202.434.4180).

Annual FCC Regulatory Fees

The FCC announced that regulatory fees for the fiscal year 2016 will be due by September 27, 2016. Licensees of certain facilities, such as Satellite Earth Stations, are required to make annual regulatory fee payments. For many licensed facilities, such as microwave and land mobile systems, the regulatory fees are paid when the application is filed with the FCC. For additional information, please contact Tim Doughty (; 202.434.4271).