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Dear USMSS Members … attached you will find a joint EWA-USMSS Petition for Reconsideration that was filed on July 9, 2007, in the above referenced proceeding. In this Petition for Reconsideration, we again requested the FCC to exempt all telecommunications carriers operating systems authorized on Part 90 channels that are not interconnected with the PSTN or do not satisfy the “covered carrier” definition. The comments note that it is unclear how the FCC expects Part 90 carriers to demonstrate that they have to protect information they do not have and why it is in the public interest to require them to conform to rules that have no applicability to the customers they serve. EWA and USMSS argued that it would not be contrary to the goals of Congress when it enacted Section 222 of the Telecommunications Act of 1996 to exempt these classes of telecommunication carriers since they do not have access to the type of information intended to be protected under the statute. We also noted that the issue is not one of cost, as interpreted by the FCC, but one of applicability.
Download EWA-USMSS Petition for Reconsideration.
Should you have any questions or comments regarding this filing, please feel free to call me. Thank you, Mark
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