Kramer Telecom Law Firm, P.C.

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Simple Math: Law + Technology = Client Solutions

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Just knowing the law is not enough . . .
...and neither is just knowing the technology.

We know both, and our clients benefit from that synergy.

Kramer Telecom Law Firm, P.C. (KTLF) is an unusual law firm combining decades of wireless telecom, cable TV, broadband, fiber technology, Internet domain names, and right-of-way technology and management with practical law knowledge in those areas. We provide our clients with real world, technology-appropriate solutions to their legal issues.

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I even have the $100.00 receipt to prove it!

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KTLF NEWS HEADLINES

CTIA’s Worst Fear:
Point-of-Sale Access to Consumer Information

August 7, 2010: The Cellular Telephone Industry Association (the CTIA) sued the City and County of San Francisco on July 23, 2010 in an attempt to overturn the City’s new ordinance requiring disclosure of the “Specific Absorption Rate” (SAR) data.  The Ordinance is titled the “Cell Phone Right-to-Know Ordinance” (Ordinance No. 155-10).

To read why the CTIA is trying so hard to kill this consumer-protection legislation, please follow this link to my cell tower siting blog. (Longer article)
Ms. Aleen Tomassian, BS Joins KTLF Staff
Aleen Tomassian

August 5, 2010:

Aleen Tomassian BS (Berkeley, '10) joined the firm's staff in July 2010 as Jonathan's newest assistant.

She steps in for Mr. Tripp May who is now on a three-year leave of absence to attend the University of San Diego Law School, and then to take the California Bar examination.

Ms. Tomassian graduated from the University of California at Berkeley in 2010 with a Bachelors of Science degree. She intends to attend law school starting in the fall of 2011.

Aleen's formal science education background has already provided to be very valuable in reaching solutions to client issues based on application of scientific analysis and systems solutions.

We're very glad that she's now a member of our team.
FCC Re-Shoots the Shot Clock Gun: Local Governments Hit

August 3, 2010: The FCC has denied reconsideration of its wireless siting shot clock ruling (FCC 09-99). The Commission opening it denial as follows:

"Last November, the Commission in a Declaratory Ruling established time frames for State and local governments to act on wireless facility siting applications. Five organizations representing local governments requested that we reconsider a portion of that ruling relating to the suspension of these time periods when an application is incomplete as filed. Today, we reaffirm our decision that the time frames –90 days for collocations and 150 days for other wireless facility siting applications – are automatically tolled only when the reviewing government notifies the applicant of the incompleteness within the first 30 days after receipt. In so doing, we promote the timely deployment of innovative broadband and other wireless services while preserving the legitimate authority of State and local governments, in furtherance of the goals of our initial decision and consistent with the recommendations of the National Broadband Plan."

To read the entire denial, please follow this link to open the PDF of the decision.

* * *

More than ever, and especially in light of the FCC's reconsideration denial, local governments should consider using a strong and structured application to collect necessary administrative record data. We make our application available for free for use by all governments.

Please follow this link to visit our wireless and DAS application download page.

Jonathan Accepted in to LL.M IT/Telecom Law Program

July 26, 2010: Jonathan has been accepted into the Master of Laws program of the University of Strathclyde, located in Glasgow, Scotland. The program, which is the oldest of its kind, focuses on advance legal issues related to information technology and telecommunications. About 100 students from over 20 countries given this unique program a truly international flavor.

Given the subject matter and the international mix of students, it's no surprise that the program is via on-line studies and candidate interactions.

Jonathan's studies begin in September, 2010 and will be concluded two years later.

Wireless Siting Form Revised, Updated

June 22, 2010: Jonathan has revised and updated the Wireless/DAS siting form used by governments around the county. If you are a government agency, you are welcome to use this form to assist you in collecting data for your administrative record.

Used by governments around the country for nearly 7 years, this form helps governments collect relevant and necessary data to assist the government with complying with Telecom Act Sections 253, 332, and 704 data collection and analysis requirements. In California, the form also assists in determining rights under PUC Code Sections 7901 and 7901.1 related to a carriers interest in siting in the public right of way, as well as CEQA and the California Government Code.

This copyrighted form is free to use and modify by federal, state, and local government agencies. See the Wireless Siting Form page for more details, and download links for the updated form in three different formats (.doc; .docx; .rtf; and .pdf). A link to the download page is also on the left column of this page.

Please visit our dedicated siting application page by following this link.

Jonathan L. Kramer's
Upcoming Lectures and Presentations

ARRL 2010 Southwest Conference:
"I'm from the Government [Planning Department] and I'm Here to Help You"

September 19, 2010: Jonathan will present his (in)famous lecture, "I'm from the Government [Planning Department] and I'm Here to Help You" lecture to the ARRL Southwest Division Convention at the Four Points Sheraton Hotel in San Diego, California.

This presentation will focus on the FCC rules and California state law that control amateur radio tower siting, and offer techniques to help move the process forward.

Note that Jonathan Kramer, an amateur radio Extra-class operator and Volunteer Counsel of the American Radio Relay League, represents local governments in these matters, so the lecture will be from that perspective.

Current Issues in Cell Tower Leasing
September 20th and 28th 2010

September 20th and 30th, 2010: Jonathan and John W. Pestle will be co-presenters on the very popular topic of 'Current Issues in Cell Tower Leasing.' These teleconferences are coordinated by Lorman Education Services.

Jonathan will focus on the technology issues (transmission, RF safety, equipment) as they intertwine with the legal issues connected with site leasing. Call it,' how carriers use techno-babble to hide their balls in your wireless leases.'

These lectures are geared towards private practice and municipal government attorneys. For more information and registration details, please click on the links below:

To register for the September 20th conference call, please click here.

To register for the September 28th conference call, please click here.

Note that continuing education participation units/credits are available for these seminars: AICP (Pending); CC; CLE/MCLE (please check Lorman's "Detailed Credit Information" page for states that have already been approved); ENG; and PMI.

Wireless Facilities Siting - How to Accommodate
Explosive Growth while Maintaining Neighborhood Livability Best Practices
September 30, 2010 (Live, in Washington D.C.)

September 30, 2010: Jonathan will be an in-person speaker at NATOA's 2010 Annual Conference talking about promoting coexistence between wireless facilities and neighborhoods. Presently, Brian Grogan of Moss & Barnett is a scheduled co-speaker, with more co-speakers to be announced.

For more information about NATOA's 30th (!) Annual Conference, visit NATOA.ORG.

Wireless 101 for Attorneys:
New Mexico Municipal League Attorneys Association Winter Meeting & Seminar, December 2010

December 2010: Jonathan will present his Wireless 101 for attorneys at the "New Mexico Municipal League Attorneys Association Winter Meeting and Seminar" (now that's a mouthful) in December.

For more information, please follow this link.

Current Issues in Cell Tower Regulation and Zoning Rules
December 2, 2010

December 2, 2010: Jonathan and John W. Pestle will be co-presenters on the extremely popular topic of 'Current Issues in Cell Tower Regulation.' The teleconference is coordinated by Lorman Education Services.

Jonathan will focus on the technology issues (transmission, RF safety, equipment) as they intertwine with the legal issues connected with cell site regulation and zoning by governments. John Pestle will take the lead on the case law and non-technical regulations (his case law handbook it simply outstanding).

This lecture is geared towards private practice and municipal government attorneys. For more information and registration details, please click on the links below:

This page will soon be updated with a registration link.

Note that continuing education participation units/credits are available for these seminars: AICP (Pending); CC; CLE/MCLE (please check Lorman's "Detailed Credit Information" page for states that have already been approved); ENG; and PMI.

Jonathan L. Kramer's List of Publications of Note

Kramer's RF Safety Article Published in the
Public Law Journal of the State Bar of California

A guide to local government attorneys and planners

The Public Law Journal of the State Bar of California has published Jonathan's article, "A Practical Guide to Radio Frequency Emissions Safety." The article appears in the Summer 2009 edition (Vol. 32, No. 3).

This guide discusses how local government agencies can properly and effectively deal with RF safety issues that come up in connection with wireless siting cases (primarily cell sites, but also broadcast, ham radio, and commercial two-way users, as well).

While written primarily for California public law attorneys, attorneys around the country will find many important and useful gems in the article.

The editor of the Public Law Journal has kindly granted permission for me to reproduce the article here in PDF format, which can be found by following this link.

I'd like to thank Javan Rad, Esq., Assistant City Attorney for the City of Pasadena, California and Robert Jystad, Esq., of the Channel Law Group for their assistance in reviewing and commenting on this paper.

Ten of Kramer's cell site photos published in
French Art Magazine, "PALAIS /"

In conjunction with a 2009 feature gallery exhibit titled, "Spy Numbers", at the Palais de Tokyo (Paris, France), they have published ten of Jonathan's camouflaged cell site photos in the art magazine, "PALAIS /". Kramer's photos appear in the article by Matt O'dell titled, "Manipulations des esprits mobiles" (their translation: "Mobile Mind Control").

Jonathan's favorite quote from the article is, "One of the most extreme conspiracy beliefs is that the masts are operating as a giant network of mind control weapons: That they are a part of a sinister plan by global governments to control the population."

Heck, I didn't know that the global governments could mount a world-wide "sinister plan"!

Jonathan Kramer Authors RF Safety Chapter
in Major New National Wireless Siting Guide

NATOA's new e-Guide to the siting of wireless facilities features a expansive chapter on RF emissions safety authored by Jonathan Kramer. This essential electronically-published Guide includes:

  • A review of federal, state and local laws on facility siting including lessons learned from court cases involving siting decisions
  • Establishing comprehensive and effective wireless zoning codes
  • How to establish a win/win relationship with facilities companies-to ensure full coverage and appropriate compensation for all parties
  • Case studies of local government and wireless carrier collaboration
  • Use of co-location, creative stealth technology and other appealing solutions for your community
  • Guidelines for dealing with radio frequency emissions safety
  • Protecting public safety communications from interference
To order your copy of the guide please visit this page at NATOA's web site.

Leakage in an All-Digital World
Heavy Hitters Weigh In

Ron Hranac's article "Signal Leakage in an All-Digital Network" in the February 2009 issue of Communications Technology magazine prompted a follow-up article with responses from (as the editor calls us) the "Heavy Hitters." That follow-on article is in the March 2009 issue of Communications Technology magazine. You find a PDF copy of the March 2009 article in the Articles section of this web site.

Click on the ARTICLES tab, above.

Give Me Your Bond
by Jonathan L. Kramer

Bonds; grounds; drops... It's an NEC Compliance Thing! Jonathan's article on these topics is the cover story in the October 2007 issue of Communications Technology magazine. (Updated October 26, 2007)

Click on the ARTICLES tab, above.

Cell Phonies

Is it a bird? A plane? A buffalo? Nope. It's a camouflaged cell phone tower site. The September 2007 issue of The National Geographic magazine features Jonathan's photographs of camouflaged cell sites. He's also quoted in the article, and he supplied additional photos for an on-line feature at the NGS web site.

Click on the ARTICLES tab, above.
(It's okay...you can click on the image!)

A Modern Game of Hide and Seek
by Jonathan L. Kramer

Want to learn about wireless site camouflaging from the perspective of government planners? In a new article by Jonathan in the July 2007 issue of AGL MAGAZINE, you'll find out!

Click on the ARTICLES tab, above.
(It's okay...you can click on the image!)

Picture Quality in the Digital Cable World: A Lost Science?
by Jonathan L. Kramer

There's a new article by Jonathan in the Summer 2007 issue of the NATOA JOURNAL.

Titled, "Picture Quality in the Digital Cable World: A Lost Science?", Jonathan discusses the history and future of the FCC's cable TV system picture quality rules and enforcement of those rules. Click on the ARTICLES tab, above.

KTLF's Story

Before becoming an attorney, Jonathan Kramer was licensed by the FCC for over 30 years. Today, he holds the highest-grade FCC commercial radiotelephone, marine digital, radar, and amateur radio licenses. Jonathan's also been licensed as a telecommunications contractor in California for over 20 years.

Jonathan has been 'on faculty' for various continuing education courses for attorneys, and he's advised hundreds of attorneys in how to deal with telecommunications technology matters. Involved in the nuts-and-bolts of radio frequency, cable TV, and broadband telecommunications for 30 years, Kramer has been recognized by industry and governments as a leader in telecommunications and regulation.

After working with so many attorneys over the decades, Jonathan recognized the need for technical expertise, coupled with a keen knowledge of law related to telecommunications, so he embarked on the long path of becoming an attorney. Today, Jonathan is admitted to practice law in California and the US District Court (Central District of California). He advises governments and public and private attorneys around the country regarding telecommunications issues.

We can help guide you through your telecommunications law issues.

Antenna Tower Siting/Planning/Ordinances Tower siting and planning is a difficult subject for many governments and private parties. It's only getting more complicated with the current round of mergers and partnerships, and the entry of new FCC licensees into the marketplace.

Is the site the least intrusive? Is the design the best possible? Is the compensation at a fair rate? What about the lease terms? We'll help you answer those and other key questions.

We over 17 years of experience in educating and assisting hundreds of governments and private parties throughout the U.S. in tower siting cases, ordinance drafting, and lease negotiations. You can plan on us to help you, too.

Radio Frequency Emissions Safety Far and away, the public's first concern with new cell tower sites is radio frequency emissions safety. The public is often quite vocal about whether a particular cell site, or a combination of cell sites will be harmful to their health. We have nearly two decades of experience addressing RF safety concerns.

Our principal attorney, Jonathan Kramer co-authored the FCC's "A Local Government Official's Guide to Transmitting Antenna RF Emission Safety: Rules, Procedures, and Practical Guidance." (Long name, but a great guide in PDF and WORD formats.) We can help you deal with the public's RF safety concerns through education and independent RF reviews.

"Furniture" in the Right-of-Way It's a really big deal...with the telephone companies entering the video market place, governments and private associations are facing the prospect of dozens to hundreds of new, large equipment cabinets in the right-of-way and common areas.

We can help you to minimize the disruption to your right of way...and your community... through careful siting of these new cabinets, and by crafting specific construction regulations that address local concerns during the construction phases.

Over-the-Air Reception Devices The FCC, as directed by Congress, as adopted sweeping rules limiting the controls state and local governments, and private parties can impose and enforce regarding over-the-air receiving (and even transmitting) antennas/devices.

Call on us...we'll help you 'receive' high-strength guidance on OTARD!

Litigation; Expert Witness Depositions; Examinations To paraphrase, 'Litigation Happens.' If you're going to litigate a matter, you need to know the in's-and-out's of the other side's case (and your own, too). In the technology areas, we can provide key insights to help you and your lead attorney frame your case, or your defense.

It's common for attorneys to depose expert witnesses in technology matters. It's uncommon for an attorney to have decades of technical depth in a subject matter area to ask the key follow-up questions of the expert.

Jonathan Kramer, KTLF's principal attorney has nearly three decades of technology experience in radio frequency communications, cable television, fiber optics, and plant safety matters. He's also been an expert witness in cable TV and wireless matters. It's that level of experience that enables us to ask the important follow-up questions to get to the real strengths and weaknesses of an expert's testimony.

Cable TV Plant Safety and Picture Quality When it's time to franchise, transfer, or renew a cable television system, two of the most valuable evaluations you can commission are in connection with physical plant safety (code compliance) and picture quality (FCC rules compliance).

Over the past 26 years, Jonathan Kramer and staff have performed and supervised tens of thousands of location safety evaluation and test point inspections for nearly 600 jurisdictions around the country.

Safety code compliance, and signal quality maintenance are top-level concerns for governments around the country. We have the experience to show you how to deal with these issues in a very practical way.

Amateur Radio Antenna IssuesAmateur radio station antennas enjoy special rights under the FCC's PRB-1 rules, and under some state laws as well. While those rules don't preempt local zoning laws, they do impact them, as Ham operators will quickly point out.

Jonathan Kramer has been licensed as an Amateur Radio operator for over 30 years. He holds the highest class amateur radio license (the "Extra Class" license; call sign W6JLK), and can translate 'Ham-speak' into English and/or Law during your zoning hearings, and when you draft a wireless ordinance that touches on amateur radio stations.

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