Impact of FCC Supply Chain ("Rip & Replace") Order on Public Safety

Updated: Feb 5

FCC has hired Widelity to produce the Catalog of Eligible Expenses.

February 3, 2021


iCERT has received a direct inquiry from Widelity, Inc. regarding the potential for iCERT Members to have incurred expenses that are eligible for reimbursement or other treatment under the FCC's program.


IF YOUR COMPANY WOULD LIKE TO FIND OUR MORE AND/OR PARTICIPATE IN THE WIDELITY INQUIRY, PLEASE CONTACT executivedirector@theindustrycouncil.org by EoD on Thursday, February 11, 2021.


Widelity has been engaged by the FCC to write a report, assemble a catalog of costs, and a list of covered communications equipment for the Supply Chain Program, usually known as the Huawei/ZTE rip and replace program. This report is the foundational information necessary to move ahead - Congress has not yet provided funding for the actual program. Should the program be funded, iCERT Members that qualify will have ample time / opportunity to apply for reimbursement.


Eligible telecommunications carriers will be removing the Huwaei and ZTE equipment from their networks and replacing it with equipment from other vendors.


Widelity would like to speak with public safety companies that will be active in the rip and replace process regarding the following:

  1. What are the challenges that the telecom companies will have maintaining their public safety commitments as they replace their network equipment? Are there any specific procedures that they will have to undetake?

  2. What are the costs that will be incurred to do the support work for the replacement process? These costs will be included in the catalog so that your clients can be reimbursed and then pay you for the necessary work.

  3. If you are planning to provide service and equipment to the telecoms on the program Widelity would like to be sure that you are included in the services list.


Background:


The FCC's 2nd Report and Order notes, "We next delegate to the Wireline Competition Bureau the responsibility to develop and finalize a Catalog of Eligible Expenses and Estimated Costs (Catalog of Eligible Expenses) to inform the Reimbursement Program. The Secure Networks Act requires the Commission to “develop a list of suggested replacements” for covered equipment and services and for applicants to submit “initial reimbursement cost estimate[s] at the time of application.” The Commission is also required to “take reasonable steps to mitigate the administrative burdens and costs associated with the application process, while taking into account the need to avoid waste, fraud, and abuse.” In the broadcast incentive auction reimbursement mechanism, the use of a catalog to estimate relocation costs played a critical role in the successful processing of reimbursement applications. We seek to duplicate that success here by using a Catalog of Eligible Expenses as suggested in the record. The catalog will identify reimbursable costs with as much specificity as possible, provide guidance to entities seeking reimbursement, streamline the reimbursement process, and increase accountability. Listing in the catalog, however, is not a guarantee of reimbursement for any individual expense, and all claimed expenses are subject to review by the Commission staff to ensure each expense and request for reimbursement is reasonable.


The Catalog of Eligible Expenses will also help the Commission and applicants satisfy the Secure Networks Act’s requirements not only by helping applicants with transition planning and estimating costs for application submissions, but also with identifying potential replacement equipment and services and expediting the Commission’s reimbursement request review process. As CCA points out, the removal, replacement and disposal of covered equipment and services in a mobile wireless network is a complex, multi-step process that is likely to encompass a range of expenses, including: drive testing to determine baseline coverage; evaluating spectrum and backhaul capabilities; ordering new equipment; installing new network core and RAN equipment; potentially leasing space on or building new towers and obtaining any associated permits and approvals; testing and optimizing the network; and migrating traffic and decommissioning covered equipment and services.394 Because there will likely be a range of expenses that could vary among providers, the Catalog of Eligible Expenses will be used to provide helpful guidance regarding the kinds and amounts of expenses that will be reimbursed. Accordingly, the Catalog of Eligible Expenses will not be a definitive list of all reimbursable expenses but a means to facilitate the reimbursement process. Given the importance of the Catalog of Eligible Expenses to the Reimbursement Program, Commission staff have already begun work to develop it, and we expect to release it as soon as possible.395"


FCC Documents

FCC 2d Report and Order Released December 11, 2020 WC Docket No. 18-89 Protecting Against National Security Threats to the Communications Supply Chain Through FCC Programs https://docs.fcc.gov/public/attachments/FCC-20-176A1.pdf


Details -

395 - The Federal Communications Commission has engaged a contractor to prepare the Catalog of Eligible Expenses. See Supply Chain Reimbursement Program Catalog of Eligible Expenses, Contract Award Number 273FCC21C0001, https://beta.sam.gov/opp/ba18962b90254b9c9af7da547d3361ae/view?keywords=%22federal%20communications%20commission%22&sort=-modifiedDate&index=&is_active=true&page=1&organization_id=100076366 (awarding contract to Widelity, Inc.).

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