Key Wireless Deadlines

FCC Proposes to Update Intercarrier Compensation Regime: In this Further Notice of Proposed Rulemaking (FNPRM), the Federal Communications Commission (FCC or Commission) "seeks comment on proposed amendments to prevent companies from attempting to evade its existing access stimulation rules, harming customers, and imposing unwarranted costs on America's telecommunications networks." Specifically, the Commission proposes "to eliminate perceived ambiguity in our rules that the record shows companies are seeking to leverage to force IXCs and their long-distance customers to continue to bear the costs of high-volume calling services by incorporating [IP enabled Providers] into the call path." Comments are due September 6, and reply comments are due October 3.

FCC Seeks Comment on Methods to Target and Eliminate Unlawful Robocalls: In this FNPRM, the Commission proposes and seeks comment on a number of actions aimed at protecting consumers from illegal calls. The document "proposes and seeks comment on a number of steps to protect American consumers from all illegal calls, whether they originate domestically or abroad." Specifically, this document proposes "to require domestic intermediate providers that are not gateway providers in the call path to apply STIR/SHAKEN caller ID authentication to calls." It also seeks comment on "a number of robocall mitigation requirements, enhancements to enforcement, clarifications on certain aspects of STIR/SHAKEN, and limitations on the use of U.S. North American Numbering Plan (NANP) numbers for foreign-originated calls and indirect number access." The comment deadline has passed, and reply comments are due September 16.

NIST Seeks Comment on AI Risk Management Framework: The National Institute of Standards and Technology (NIST) released its (1) AI Risk Management Framework: Second Draft and (2) AI RMF Playbook. The AI RMF Second Draft "builds on the initial March 2022 version and the December 2021 concept paper" and "reflects and incorporates the constructive feedback received." The AI RMF Playbook "provides actions Framework users could take to implement the AI RMF by incorporating trustworthiness considerations in the design, development, use, and evaluation of AI systems." Comments on both documents are due September 29.

NCCoE Requests Comment on Mitigating AI Bias: The National Cybersecurity Center for Excellence (NCCoE) released a new Draft Project Description, Mitigating AI/ML Bias in Context: Establishing Practices for Testing, Evaluation, Verification, and Validation of AI Systems. The purpose of this project is to develop domain-specific testing, evaluation, verification, and validation (TEVV) guidance for detecting bias; recommendations for bias mitigation; and recommended practices for humans involved in automated decision-making processes in a specific context (consumer and small business credit underwriting). As part of the project, NCCoE will release an AI/ML Practice Guide. Comments are due September 16.

NIST Seeks Comment on Information and Communications Technology Enterprise Risk Management: NIST released two new documents focused on information and communications technology (ICT) enterprise risk management (ERM). Draft SP 800-221A, Information and Communications Technology (ICT) Risk Outcomes: Integrating ICT Risk Management Programs with the Enterprise Risk Portfolio, provides a set of desired outcomes and applicable references common across all types of ICT risk, and provides a common language for understanding, managing, and expressing ICT risk to internal and external stakeholders. Draft SP 800-221, Enterprise Impacts of Information and Communications Technology Risk: Governing and Managing ICT Risk Programs Within an Enterprise Risk Portfolio, seeks to promote a greater understanding of the relationship between ICT risk management and ERM and the benefits of integrating those approaches. The comment deadline for both publications is September 6.

NIST Requests Comment on Protecting Controlled Unclassified Information in Nonfederal Systems: NIST announced a Pre-Draft Call for Comments on its SP 800-171 series on controlled unclassified information (CUI). NIST seeks feedback on the use, potential updates, and opportunities for improvement to SP 800-171 Rev. 2, and its supporting publications – SP 800-171A, SP 800-172, and SP 800-172A. This publication "provides agencies with recommended security requirements for protecting the confidentiality of CUI when the information is resident in nonfederal systems and organizations; when the nonfederal organization is not collecting or maintaining information on behalf of a federal agency or using or operating a system on behalf of an agency; and where there are no specific safeguarding requirements for protecting the confidentiality of CUI prescribed by the authorizing law, regulation, or governmentwide policy for the CUI category listed in the CUI Registry." Comments are due September 16.

Upcoming Meetings and Events

NIST Federal Cybersecurity & Privacy Professionals Forum Meeting: On September 1, NIST's Federal Cybersecurity and Privacy Professionals Forum will meet. More details can be found here.

13th Annual Billington Cybersecurity Summit: On September 7-9, many Department of Homeland Security (DHS)-affiliated and other cybersecurity speakers will be presenting during the Billington Cybersecurity Summit. More information is available here.

NORS Outage Information Sharing Workshop: On September 7, the FCC will be hosting a workshop for federal, state, territories, Tribal agencies, and agencies of the District of Columbia that will soon be eligible to access the FCC's Network Outage Reporting System (NORS) and Disaster Information Reporting System (DIRS). More details are available here.

FTC Public Forum on Trade Regulation Rule on Commercial Surveillance and Data Security: On September 8, the Federal Trade Commission (FTC) will hold a public forum regarding its recent data privacy Advance Notice of Proposed Rulemaking (ANPRM). More information can be found here.

WRC-23 Advisory Community Meeting: On September 12, the FCC's World Radiocommunication Conference Advisory Committee will be holding its sixth meeting. More details can be found here.

FCC Workshop on Environmental Compliance and Historic Preservation Review Procedures: On September 13, the Wireless Telecommunications Bureau will host a workshop on the environmental compliance and historic preservation review procedures needed for the construction of communications facilities supporting FCC licensed services. More information is available here.

Future Security Forum 2022: On September 13, Cybersecurity and Infrastructure Security Agency (CISA) Director Jen Easterly is speaking at the virtual Future Security Forum on Securing Democracies, which is hosted in part by New America. More information can be found here.

NTIA 2022 Spectrum Policy Symposium: On September 19, the National Telecommunications and Information Administration (NTIA) will hold a symposium on radio-frequency spectrum. More information is available here.

NCCoE DevSecOps Workshop: On September 19, NIST's NCCoE will hold a virtual workshop on DevSecOps. More details can be found here.

CSRIC VIII Meeting: On September 21, the FCC's Communications Security, Reliability, and Interoperability Council (CSRIC) VIII will meet. More information can be found here.

FCC Open Meeting: The next FCC Open Meeting is scheduled for September 29. Once available, more details will be available here.

Did You Know?

TMT partner Amb. David Gross was awarded "Lawyer of the Year" in the 2023 edition of The Best Lawyers in America® among the total of 54 Wiley attorneys recognized. Learn more here.

TMT partner Josh Turner and associates Sara Baxenberg and Travis Stoller filed an amicus brief on behalf of the Association for Uncrewed Vehicle Systems International (AUVSI) that was used by the D.C. Circuit in a decision that reinforced the constitutionality of drone remote ID. Learn more here.

Wiley created a Sanctions and Export Controls Resource Center, which hosts our latest insights related to sanctions, export controls, digital currency, cybersecurity and privacy, and other issues surrounding Russia's invasion of Ukraine.

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