FCC Announces Limited Modification of Ex Parte Rules for C-Band Transition

On November 18, 2020, the Wireless Telecommunications Bureau (“the Bureau”) released a Public Notice announcing a limited modification of the FCC’s ex parte rules in the C-Band transition matter (GN Docket No. 18-122, IB Docket No. 20-205, GN Docket No. 20-305) for communications between the C-Band Transition Relocation Coordinator, Relocation Payment Clearinghouse, and FCC staff.  You may recall that on September 25, 2020, the Bureau approved RSM US LLP (“RSM”) as the Relocation Coordinator for the C-Band transition process to handle and coordinate the relocation actions among eligible Fixed Satellite Service (“FSS”) space station operators, incumbent FSS earth station operators, and new 3.7 GHz Service overlay licensees.  Additionally, on October 22, 2020, the Bureau approved CohnReznick LLP and subcontractors Squire Patton Boggs (US) LLP and Intellicom Technologies, Inc. (collectively “CohnReznick”) as the Clearinghouse to handle all cost-related aspects of the transition.


In order to effectively administer the transition, the Bureau recognizes that FCC staff, RSM, and CohnReznick must communicate on an ongoing basis.  In order to effectuate a seamless and timely transition, the Bureau is exempting any C-Band transition presentations made between or among FCC staff, RSM, and CohnReznick from the FCC’s ex parte rules.  The Bureau notes, however, that only information in the public record may be relied upon by the FCC or Bureau for decisions made in the proceeding.  Additionally, RSM and CohnReznick are directed to file regular status reports in the record and on their websites.


The notice applies only to communications made by RSM or CohnReznick to the FCC; all other communications are subject to the “permit but disclose” requirements.


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