Yesterday, the FCC announced that on November 18, 2022, it will release a “pre-production draft” of its widely anticipated broadband maps, which will contain granular information about existing broadband infrastructure and service availability in the U.S. The maps, which the FCC was required by law to develop, will be used by the Department of Commerce’s National Telecommunications and Information Administration (“NTIA”) to distribute $42.5 billion in funding to states for allocation to service providers who will use it to construct additional broadband networks.

The federal government’s allocation of these funds is pursuant to the Broadband Equity, Access, and Deployment (“BEAD”) Program, which was established by the Infrastructure Investment and Jobs Act (“IIJA”) in November 2021. Click here for our summary of the BEAD Program.

The FCC began this particular mapping initiative in August 2019. Doing so marked a departure from the agency’s prior mapping efforts, which had acknowledged gaps. The new initiative was informed in part by the March 2020 Broadband DATA Act, which required the FCC to collect granular data about geographic areas in which broadband infrastructure exists, as well as attributes such as download and upload speeds and latency. 

To ensure accuracy and avoid over- or under-funding certain locations, the FCC incorporated a “challenge process” into its broadband map development, through which governmental entities, broadband service providers, and others are able to submit bulk challenges to the data that the FCC collected. The FCC believes that this process will help it refine its maps before subsequent versions are released.

On the same day as the FCC announcement, NTIA stated that it expects to announce each state’s BEAD allocation by June 30, 2023. NTIA encouraged the public to view January 13, 2023 as the date by which parties should submit challenges in time for the FCC to include corrections in the version of the map that will determine these allocation decisions. In announcing the June 2023 target date for allocations, NTIA provided some certainty to states eager to learn of their allocations and providers eager to compete for funding. Nevertheless, the challenge process between now and then likely will be robust with $42.5 billion at stake. It also bears mentioning that states will have to take additional steps to receive funding after the allocation announcements, so the date on which funds will begin to flow to providers remains to be determined.

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.”

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.

Photo of Jocelyn Jezierny Jocelyn Jezierny

Jocelyn Jezierny is an associate in Covington’s Technology and Communications Regulation practice group, where she counsels clients on a broad range of matters in the technology, media, and communications industries.

In particular, Jocelyn advises clients on a wide range of issues before the…

Jocelyn Jezierny is an associate in Covington’s Technology and Communications Regulation practice group, where she counsels clients on a broad range of matters in the technology, media, and communications industries.

In particular, Jocelyn advises clients on a wide range of issues before the Federal Communications Commission (“FCC”) and state public utility commissions, including licensing matters, transaction approvals, and rulemaking proceedings. Jocelyn assists telecommunications and media clients in responding to investigations before both the FCC and the Federal Trade Commission (“FTC”) and in participating in proceedings before an Administrative Law Judge. Jocelyn has significant experience in matters involving foreign investment in FCC-regulated companies.

Jocelyn also advises on regulatory and legal considerations related to emerging technologies such as Artificial Intelligence (“AI”) and the Internet of Things (“IoT”).

Jocelyn maintains an active pro bono practice in which she advises on a variety of issues, including assisting U.S. military veterans in seeking upgrades to their medical benefits and advising small media organizations and independent journalists on a variety of legal and regulatory matters.

Prior to joining Covington, Jocelyn was an Attorney-Advisor in the FCC’s International Bureau (now the Office of International Affairs), where she worked on matters pertaining to the licensing of foreign-owned U.S. telecommunications services providers. Jocelyn has developed significant experience in working for and with federal agencies.