On December 1, I reviewed a Notice of Proposed Rulemaking affecting Chapter 55 of the Oklahoma Corporation rules (Telecommunications). Although these notices usually do not affect PSAPs -- Public Safety Answering Points (a.k.a. 9-1-1 Call Centers) -- this one does. Accordingly, I contacted several knowledgeable people in government and in emergency communications particularly, and have determined that the rule as proposed may not be objectionable, despite my first inclination to oppose it. The rule to be amended in Oklahoma Administrative Code Section 165:55-3-2 would eliminate the provision for notifying a public body of an application for a certificate of convenience and necessity (CCN) by a telecommunication applicant proposing to operate in the territory the PSAP covers. Instead, the CCN applicant would only need to notify Attorney General (as before), and also the Oklahoma 911 Management Authority State Coordinator's Office (instead of the PSAPs in the territory). Adoption of recent legislation effective November 1, to move collection of wireline (traditional) telephone 911 fees from local collection to the Oklahoma Tax Commission, has reduced the need to local agencies to track the telecommunications companies. See Okla. Laws 2023, Chapter 258 (HB 1590). LINK to current statute: Collection and Apportionment of Prepaid 9-1-1 Fees - Monthly Report (oscn.net)<https://www.oscn.net/applications/oscn/DeliverDocument.asp?CiteID=478822>. Moreover, upgrades in telecom protocols has greatly diminished the likelihood of technical incompatibility. So in short I do not plan to file comments on the rule. Deadlines for this rulemaking are: 01-04-2024 technical conference 1:30 p.m. 01-15-2024 comments deadline 01-25-2024 technical conference 1:30 p.m. 02-08-2024 adoption hearing 1:30 p.m. 165:55-3-2. Notice requirements when filing an Application for Certificate of Convenience and Necessity Applicants seeking a Certificate of Convenience and Necessity CCN shall meet all notice requirements as set forth in this Section. Requirements for filing an Application of a Certificate of Convenience and Necessity a CCN application. An Application of a Certificate of Convenience and Necessity A filed CCN application shall be delivered by mail, electronic mail or by personal service to the following people and/or entities: (A) The Attorney General of the State of Oklahoma; (B) The Commission's PUD Director of the Public Utility Division of the Oklahoma Corporation Commission … (C) The Oklahoma 911 Management Authority State Coordinator's Office governing body of each Enhanced 911 Public Safety Answering Point (E911 PSAP) operating in the proposed service territory of the Applicant. (D) The ILEC in the proposed service territory. …. Case No. RM 2023-000017 – RM2023-000017_2_Proposed_Rules_1701442223643-RM2023-000017_PROPOSED_RULES.pdf (ok.gov)<https://gcc02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fpublic.occ.ok.gov%2FWebLink%2FDocview.aspx%3Fid%3D14219054&data=05%7C02%7Corval.jones%40okc.gov%7C61ebd618997e4997577408dbfd7f4f42%7C837e0d97dd9d4d0097e688f05a32ee59%7C0%7C0%7C638382495483677272%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=gBpSmzZq30WFsORdTd9bHg2rGeMzoDZX8R61Q7C3GwY%3D&reserved=0> OAC 165:55 (Pages 13-14 of 46). I promised at the most recent OAMA monthly luncheon to supply my analysis if warranted. Orval Edwin Jones Assistant Municipal Counselor City of OKC CONFIDENTIALITY NOTE: This e-mail message and any attachments are intended solely for the person to which it is addressed and may contain privileged and confidential information protected by law. If you have received this communication in error, please notify the sender immediately by telephone or e-mail, destroy this message and delete any copies held in your electronic files. Unauthorized use and/or re-disclosure may subject you to penalties under applicable state and federal laws.