The FCC has announced the filing of a petition for reconsideration by the Critical Messaging Association (CMA) requesting that the FCC reconsider, in part, its July 13, 2018 Third Report and Order streamlining the licensing rules for the Cellular Service and other Part 22 licensees. Specifically, CMA requests that the FCC reverse its interpretation that rule section 90.168 applies to Part 22 licensees and requires them to submit annual Equal Employment Opportunity complaint reports irrespective of the deletion of rule section 22.321(c). In that order, the FCC deleted rule section 22.321(c) finding it duplicative with rule section 1.815, which requires all common carriers with at least 16 full-time employees to submit annual reports, and entirely subsumed within 90.168, which requires the submission of annual reports regardless of the licensee’s size. CMA argues that the FCC’s novel interpretation that rule section 90.168 applies to all Commercial Mobile Radio Service licensees, including Part 22 licensees, should be reversed. Oppositions must be filed within 15 days of the publication of the Public Notice in the Federal Register, and replies to oppositions are due 10 days later.