At the Federal Communications Commission’s (FCC’s) Open Meeting in late October, the agency unanimously adopted a Notice of Proposed Rulemaking (NPRM) that proposes to end certain legacy interconnection obligations of Local Exchange Carriers (LECs) to accelerate the transition to all Internet Protocol (IP) networks.

Currently, certain LECs are required to maintain legacy time-division multiplexing (TDM) network equipment pursuant to the Telecommunications Act of 1996 (the Act) and related FCC rules. According to the NPRM, these LEC-specific obligations are impeding the transition to next-generation communication networks, which are reputed to be more resilient, flexible, and feature-rich.  The NRPM aims to eliminate certain rules and establish a new FCC regulatory framework that would facilitate the transition to all-IP based networks, including for voice services.

The NRPM seeks comment on a number of questions, including those relating to:

  • the current state of interconnection, both for legacy voice services and for iVoIP providers;
  • a proposal to remove the LEC-specific interconnection obligations as of December 31, 2028, by forbearing from section 251(c)(2) of the Act and aspects of 251(c)(6) of the Act relating to LEC-specific requirements for physical collocation of interconnection equipment;
  • additional FCC rules or statutory frameworks affected by eliminating these certain LEC-specific interconnection obligations;
  • whether and how the FCC should modify its interconnection regulatory framework for iVoIP services; and
  • whether the FCC would need to classify iVoIP service as a “telecommunications service” to set rules for IP-to-IP interconnection for VoIP, or if it can rely on other sources of authority.

In short, the NPRM raises major questions about the future of voice calling in the United States.  The turnoff of the TDM network in the U.S. will be a major undertaking, but the FCC has signaled a willingness to contend with the hard questions surrounding that transition.    

Interested parties may submit comments in response to the FNPRM within 30 days of it being published in the Federal Register.

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Photo of Yaron Dori Yaron Dori

Yaron Dori has over 25 years of experience advising technology, telecommunications, media, life sciences, and other types of companies on their most pressing business challenges. He is a former chair of the firm’s technology, communications and media practices and currently serves on the…

Yaron Dori has over 25 years of experience advising technology, telecommunications, media, life sciences, and other types of companies on their most pressing business challenges. He is a former chair of the firm’s technology, communications and media practices and currently serves on the firm’s eight-person Management Committee.

Yaron’s practice advises clients on strategic planning, policy development, transactions, investigations and enforcement, and regulatory compliance.

Early in his career, Yaron advised telecommunications companies and investors on regulatory policy and frameworks that led to the development of broadband networks. When those networks became bidirectional and enabled companies to collect consumer data, he advised those companies on their data privacy and consumer protection obligations. Today, as new technologies such as Artificial Intelligence (AI) are being used to enhance the applications and services offered by such companies, he advises them on associated legal and regulatory obligations and risks. It is this varied background – which tracks the evolution of the technology industry – that enables Yaron to provide clients with a holistic, 360-degree view of technology policy, regulation, compliance, and enforcement.

Yaron represents clients before federal regulatory agencies—including the Federal Communications Commission (FCC), the Federal Trade Commission (FTC), and the Department of Commerce (DOC)—and the U.S. Congress in connection with a range of issues under the Communications Act, the Federal Trade Commission Act, and similar statutes. He also represents clients on state regulatory and enforcement matters, including those that pertain to telecommunications, data privacy, and consumer protection regulation. His deep experience in each of these areas enables him to advise clients on a wide range of technology regulations and key business issues in which these areas intersect.

With respect to technology and telecommunications matters, Yaron advises clients on a broad range of business, policy and consumer-facing issues, including:

Artificial Intelligence and the Internet of Things;
Broadband deployment and regulation;

IP-enabled applications, services and content;
Section 230 and digital safety considerations;
Equipment and device authorization procedures;
The Communications Assistance for Law Enforcement Act (CALEA);

Customer Proprietary Network Information (CPNI) requirements;

The Cable Privacy Act
Net Neutrality; and
Local competition, universal service, and intercarrier compensation.

Yaron also has extensive experience in structuring transactions and securing regulatory approvals at both the federal and state levels for mergers, asset acquisitions and similar transactions involving large and small FCC and state communication licensees.

With respect to privacy and consumer protection matters, Yaron advises clients on a range of business, strategic, policy and compliance issues, including those that pertain to:

The FTC Act and related agency guidance and regulations;
State privacy laws, such as the California Consumer Privacy Act (CCPA) and California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Virginia Consumer Data Protection Act, and the Utah Consumer Privacy Act;
The Electronic Communications Privacy Act (ECPA);
Location-based services that use WiFi, beacons or similar technologies;
Digital advertising practices, including native advertising and endorsements and testimonials; and

The application of federal and state telemarketing, commercial fax, and other consumer protection laws, such as the Telephone Consumer Protection Act (TCPA), to voice, text, and video transmissions.

Yaron also has experience advising companies on congressional, FCC, FTC and state attorney general investigations into various consumer protection and communications matters, including those pertaining to social media influencers, digital disclosures, product discontinuance, and advertising claims.

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Photo of Matthew DelNero Matthew DelNero

Matt DelNero provides expert regulatory counsel to companies of all sizes in the telecommunications, technology and media sectors. As a former senior official with the FCC and longtime private practitioner, Matt helps clients achieve their goals and navigate complex regulatory and public policy…

Matt DelNero provides expert regulatory counsel to companies of all sizes in the telecommunications, technology and media sectors. As a former senior official with the FCC and longtime private practitioner, Matt helps clients achieve their goals and navigate complex regulatory and public policy challenges.

Matt serves as co-chair of Covington’s Technology & Communications Regulation (“TechComm”) Practice Group and co-chair of the firm’s Diversity, Equity, & Inclusion initiative.

Matt advises clients on the full range of issues impacting telecommunications, technology and media providers today, including:

Structuring and securing FCC and other regulatory approvals for media and telecommunications transactions.
Obtaining approval for foreign investment in broadcasters and telecommunications providers.
Broadband funding under federal and state programs, including under the FCC’s Universal Service Fund (USF) and NTIA’s Broadband Equity, Access, and Deployment (BEAD) Program.
Representing broadcasters, media networks, and other content owners and producers on both existing and proposed FCC regulations and policies.
FCC enforcement actions and inquiries.
Online video accessibility, including under the Communications and Video Accessibility Act (CVAA) and Americans with Disabilities Act (ADA).
Equipment authorizations for IoT and other devices.
Spectrum policy and auctions, including for 5G.
Privacy and data protection, with a focus on telecommunications and broadband providers.

Matt also maintains an active pro bono practice representing LGBTQ+ and other asylum seekers, as well as veterans petitioning for discharge upgrades—including discharges under ‘Don’t Ask, Don’t Tell’ and predecessor policies that targeted LGBTQ+ servicemembers.

Prior to rejoining Covington in January 2017, Matt served as Chief of the FCC’s Wireline Competition Bureau. He played a leading role in development of policies around net neutrality, broadband privacy, and broadband deployment and affordability under the federal Universal Service Fund (USF).

Chambers USA ranks Matt within “Band 1” in his field and reports that he is a “go-to attorney for complex matters before the FCC and other federal agencies, drawing on impressive former government experience.” It also quotes clients who praise him as “an outstanding regulatory lawyer…[who] understands the intersection between what’s important for the client’s operations and how the law impacts those operations.”

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Kiara Ortiz

Kiara Ortiz is an associate in the firm’s Washington, DC office. She is a member of the Technology and Communications Regulation Practice Group.

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