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DWT
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Admitted to Practice

  • Maryland, 2000
  • District of Columbia, 2002
  • U.S. Court of Appeals D.C. Circuit, 2012

Languages

  • French

Danielle Frappier

FrappierDanielle
Partner
T202.973.4242
F202.973.4499
Danielle Frappier counsels communications entities regarding legal and regulatory matters, including compliance, market entry, licensing, and regulatory fees, with a particular focus on universal service matters, including contribution, and the Lifeline, E-rate, and High Cost/CAF programs.

Danielle leads the firm's Lifeline program team, and is deeply involved in policy, legal and business matters for her clients at both the federal and state levels. She represents multiple top-10 eligible telecommunications carriers ("ETCs"). She has obtained ETC designations and assisted with regulatory compliance for clients in over twenty-five states. At the federal level, Danielle advocates for Lifeline ETCs on a daily basis before the FCC and the program administrator, USAC.

She is also a co-chair of the firm’s E-rate program team. She represents many large and small providers of E-rate services, such as cable operators, telecommunications providers and equipment suppliers. Her experience in E-rate includes successfully guiding a client through a multi-year audit of its E-rate funding, appealing denials of funding, and responding to PIA reviews. Danielle was heavily involved in the FCC’s recent E-rate modernization proceeding in which she represented multiple stakeholders that successfully influenced the final rules that were adopted.

Danielle is a "go to" lawyer for USAC audits of Lifeline, E-rate and High Cost disbursements, as well as audits of universal service contributions (USF fees and FCC Form 499 reporting). She represents many large and small entities navigate the byzantine USF contribution rules and requirements.

Her experience also includes designing and managing comprehensive regulatory compliance programs for multiple telecommunications service providers, including foreign-based carriers providing service in the United States. She also has experience in counseling the governments and operators in developing countries regarding the policy, legal and regulatory reforms necessary to build a dynamic telecommunications sector. A native English speaker, Danielle has advised governments and operators in French-speaking Africa. Danielle holds French and U.S. citizenship.

Representative Experience

ETC Designation and FCC Compliance Plans

National counsel

Acts as national counsel to multiple top-10 Lifeline ETCs, at both the state and national levels, in over twenty-five states. (Ongoing)

ETC designations

Regularly obtains ETC designations for wireline and wireless carriers. (Ongoing)

FCC compliance plans

Drafted and is negotiating the approval of multiple FCC compliance plans for Lifeline forbearance carriers. (Ongoing)

Audits and Regulatory Inquiries

USAC audits

Guiding multiple service providers through USAC audits, and has successfully saved clients significant liability in prior audits by providing guidance from the onset of the audit. (Ongoing)

Federal and state inquiries

Advises multiple clients, in the context of federal and state inquiries, in universal service matters that help clients avoid inquiries from becoming investigations. (Ongoing)

Regulatory Compliance

Implementation of FCC Lifeline reform order

Guiding multiple top-10 Lifeline providers through the maze of new Lifeline program rules at the federal and state levels. (Ongoing)

New federal and state rules

Assists Lifeline clients on a daily basis in interpreting the application of these new rules to their back office operations, service plan structure, advertising, service terms, and virtually all aspects of their operations. (Ongoing)

Future audit planning

Assisted providers in revising their customer certification forms, revising customer care scripts, changing database procedures to ensure compliance and avoid future audit liability. (2012)

Obtaining Universal Service Funding

Pilot program - Lifeline broadband

Drafting an application for a client seeking to participate in the Lifeline broadband pilot program. (Ongoing)

FCC Forms 497, 470 and 471, item 21 attachments

Regularly advises clients on the FCC Form 497 for the Lifeline program and E-rate funding request documents, including the supporting documentation necessary to justify funding sought. (Ongoing)

E-rate bidding

Advised a client on crafting its response to an E-rate RFP in order to ensure compliance with E-rate rules. (2012)

USAC appeals

Successfully appealed denials of E-rate and High Cost funding. (2012)

Advocacy

FCC, USAC, PUC lobbying

Advocates with key FCC, USAC and state public utility commission personnel on a daily basis for Lifeline clients. (Ongoing)

Comments and rulemaking proceedings

Regularly files comments at the FCC and state commissions to advocate for clients, and has particular expertise in the interaction between state and federal regulation of telecommunications carriers. (Ongoing)

Additional Qualifications

  • Senior Legal and Regulatory Advisor, Telecommunications Management Group, Inc., Arlington, VA, 2006-2008
  • Associate, Cole, Raywid & Braverman LLP, Washington, D.C., 2000-2006

Professional & Community Activities

  • Federal Communications Bar Association
  • District of Columbia Bar Association
  • State Bar of Maryland
lifeline program blog
 e-rate program blog
blog for insight and commentary on the deployment of communications infrastructure