WASHINGTON, D.C.—On behalf of long-time client the Rural Wireless Association (RWA), Womble Bond Dickinson attorneys Carri Bennet and Erin Fitzgerald have filed an ex parte letter with the FCC responding to a draft FCC Notice of Proposed Rulemaking concerning communications supply chain security.
The proposal in question, which is expected to be considered at the FCC's April 17 Open Meeting, would seek to prohibit the use of Universal Service Fund support "to purchase equipment or services from any communications equipment or service providers identified as posing a national security risk to communications networks or the communications supply chain."
In its letter, RWA says that while the intent of the rule is to promote national security, it both falls short of that intent and may do unintentional harm to rural broadband providers and the customers they serve. The Universal Service Fund, or USF, provides subsidies to promote universal access to telecom services throughout the country. So a measure targeting USF funding would disproportionately impact rural America.
"RWA shares the Commission's desire to ensure the security of America's communications networks, and recognizes the critical role that these communications networks play in protecting public safety and national security, Bennet, who serves as RWA General Counsel, said. "However, RWA is concerned that, if adopted, the rule as proposed would not only fail to effectively protect national security; but also shut down broadband services and deter future deployment in many parts of rural America."
Instead, the RWA calls on the FCC to create a comprehensive system of security standards and testing that apply to all suppliers of government products and services, not just those that receive USF funds. Specifically, the RWA calls on the FCC to build on the comprehensive security work already done by the Communications Security, Reliability, and Interoperability Council (CSRIC).
Click here to read the RWA's full ex parte in response to the FCC Notice of Proposed Rulemaking.
Headquartered in Washington, D.C., RWA - the Rural Wireless Association is a trade association representing rural wireless carriers who each serve fewer than 100,000 subscribers. RWA's members have joined together to spread the delivery of new, efficient and innovative wireless technologies to remote and underserved communities.
Carri Bennet has more than three decades of experience representing wireline, wireless and broadband communications providers, as well as commercial and noncommercial broadcasters, in regulatory compliance matters. She has a particular focus on advocating for small rural carriers, including serving as General Counsel to the Rural Wireless Association. Bennet represents telecom industry clients before the FCC, state regulatory agencies, the courts, and Congress.
Erin Fitzgerald advises telecommunications carriers, broadband service providers, and technology companies on complex commercial and regulatory matters. Erin also serves as Regulatory Counsel to the Rural Wireless Association and has extensive experience on issues regarding privacy/data protection, spectrum auctions, universal service, broadband deployment, data roaming, network neutrality, and wireless licensing. Erin advocates in rulemaking and policymaking proceedings on behalf of RWA as well as individual clients, and frequently appears before the Federal Communications Commission (FCC).
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