Congress Passes Bill to Secure Communications Network Supply Chains from National Security Threats

On October 27, the Senate passed the H.R. 3919, the Secure Equipment Act of 2021. The lead sponsors of the legislation are Reps. Steve Scalise and Anna Eshoo. The House of Representatives passed the bill earlier this month, meaning that H.R. 3919 is going on to the White House for signature. Once signed into law, H.R. 3919 will shore up the FCC authority to withhold license authorization for equipment or services offered by companies deemed to pose a national security risk – such as companies linked to authoritarian China. The text of the enrolled bill for H.R. 3919 is available online.

City's Preferential Treatment of Fiber-Based Broadband Raises Competition Concerns

In July 2020, the City Council of West Des Moines, Iowa, voted (1) to spend $50 million to construct within public rights-of-way (ROW) a so-called "open access conduit network" that it readily concedes is designed for the exclusive use of fiber-to-the-premises (FTTP) broadband providers, and (2) to enter an "anchor tenant" agreement with Google Fiber that raises serious factual questions as to the ability of even other fiber-based Internet service providers (ISPs) to utilize that infrastructure on reasonably equitable terms.

Given that West Des Moines (the City) also serves as the gatekeeper to those ROW, these actions inevitably create worrisome conflicts of interest. They also violate the principle of technological neutrality and are at direct odds with our nation's longstanding and proven (intramodal as well as intermodal) competition-based approach to the deployment and expansion of broadband access. Moreover, given the abysmal financial track record of municipal involvement in the broadband marketplace generally, a topic I addressed in an August 2021 Perspectives from FSF Scholars, they unnecessarily place taxpayers in economic jeopardy.

MCC Iowa LLC, a subsidiary of Mediacom Communications Corporation (Mediacom), is the local cable system operator in West Des Moines. It provides broadband service throughout the City via a hybrid fiber coaxial (HFC) network at speeds up to a gigabit (1000 megabits per second (Mbps)) downstream and 50 Mbps upstream. Notably, these rates far exceed not only the definition of "broadband" embraced by the Federal Communications Commission (FCC or Commission) – 25/3 Mbps – but also the threshold for a "served" area agreed to by a bipartisan group of Senators in the $1.2 trillion infrastructure bill currently before the House – 100/20 Mbps.

Mediacom is able to provide this level of service to City residents only because it has (1) committed the large amounts of private capital required to build out its network, and, critically, (2) complied with the City's formal permitting processes in order to gain access to ROW.

In May of this year, Mediacom filed with the FCC a Petition for Expedited Declaratory Ruling (Petition) pursuant to Section 253 of the Telecommunications Act of 1996 arguing that the City's actions, which reduce substantially the construction and permitting obligations of fiber-based providers – and, as a result, their costs and time to market – as a practical matter constitute an "effective prohibition" under Section 253 for providers other than Google Fiber. This is particularly so for broadband providers that embrace distribution technologies other than end-to-end fiber (for example, cable HFC networks rely upon coaxial cable for the last-mile connection to the home) and therefore are foreclosed, at least in part, from utilizing this taxpayer-funded infrastructure.

More recently, the City and Mediacom informed the Commission on October 15, 2021, that they have agreed, at least at a high level, to resolve this dispute. As a result, the FCC's Wireline Competition Bureau issued an Order earlier this week pausing the pleading cycle in order to provide the parties with additional time to hammer out the specific details of a settlement.

The fact remains, however, that the City's underlying decision to align its economic interests with a specific distribution technology (if not a specific company utilizing that distribution technology) violates the competition-fostering principle of technological neutrality, incentivizes the City to perform its permitting function in a discriminatory fashion, and arguably implicates Section 253 itself.

Given that Mediacom and the City are in the process of negotiating specific settlement terms, it is conceivable that at least some of the disputed provisions of the City's agreement with Google Fiber will change. In one important respect, that is something we already have observed: a month after Mediacom filed its Petition, the City and Google Fiber agreed to reduce the length of time that the latter would have exclusive use of completed portions of the conduit network from 18 to 6 months.

Accordingly, at this time I will not discuss in detail other aspects of the agreement, particularly those relating to the implications of the conduit network's technical design for other providers, whether fiber-based or not. (I will note, however, that Mediacom's Petition did make numerous compelling allegations regarding the practical ability of other fiber-based ISPs to utilize the conduit network in a manner equivalent to that afforded Google Fiber.)

Instead, I want to highlight a more fundamental question raised by the City's decision to not just express a preference for fiber-based service, but to take substantial steps to reduce the costs and administrative burdens solely for fiber-based providers: Should a municipality's actions to promote a specific distribution technology be evaluated under Section 253?

As Free State Foundation President Randolph May and I explained in "Biden Broadband Plan: 'Future Proofing' Is Likely 'Fool's Proofing'," a June 2021 Perspectives, progress towards reaching the goal of universal broadband access hinges upon adherence to the pro-competitive principle of technological neutrality.

The United States is a large nation, one that encompasses areas with vastly different geographic features and population densities. Truly ubiquitous broadband coverage, as well as price competition and heightened innovation, will be realized only through policies that embrace the unique strengths and weaknesses of the range of distribution technologies – not just FTTP but also cable HFC networks, mobile and fixed 5G, fixed wireless, and satellite – that ISPs leverage to provide consumers with the capacity that they in fact demand.

As such, a policy approach that exclusively prioritizes fiber – for example, the Biden Broadband Plan as articulated in a March 2021 White House Fact Sheet – is wasteful and ultimately counterproductive. But when pursued by a municipality, is it also at odds with the pro-competitive thrust of the Telecommunications Act of 1996, specifically Section 253?

Section 253(a) states that "[n]o State or local statute or regulation, or other State or local legal requirement, may prohibit or have the effect of prohibiting the ability of any entity to provide any interstate or intrastate telecommunications service" (emphasis added). And subsection (d) empowers the Commission to "preempt the enforcement of such statute, regulation, or legal requirement to the extent necessary to correct such violation or inconsistency."

Per the FCC's 2018 Declaratory Ruling and Third Report and Order, (1) "a state or local legal requirement constitutes an effective prohibition if it 'materially limits or inhibits the ability of any competitor or potential competitor to compete in a fair and balanced legal and regulatory environment'" (emphasis added), and (2) "an insurmountable barrier is not required to find an effective prohibition under Section 253(a)."

It seems evident that the City, in choosing to spend $50 million on a conduit network that can be used only by those ISPs that embrace a FTTP model, is making it relatively more difficult for providers utilizing other viable distribution technologies to compete.

In its Opposition to Mediacom's Petition, Google Fiber dedicates an entire section to the concern that the grant of Mediacom's requested relief could have "broad, negative implications on local investment in broadband infrastructure." In response, I offer the following two points. One, as Free State Foundation scholars have pointed out on many occasions, attempts by municipalities to enter the broadband marketplace overwhelmingly have failed to achieve independent financial viability. (See the "Further Readings" at the end of this recent Perspectives from FSF Scholars for examples.) Consequently, those claimed "broad, negative implications" in fact, may generate positive economic outcomes for taxpaying residents.

Two, where the policies and/or spending by a municipality discriminate so heavily in favor of a specific provider (as alleged here, Google Fiber) or a subset of providers (as freely acknowledged here by the City, those ISPs that embrace a FTTP model), does a line exist that, once crossed, benefits one or more competitors rather than, as Congress intended in 1996, competition?

If so, a scenario may arise where preemption pursuant to Section 253(d) by the FCC of a project that so strongly rejects the principle of technological neutrality is warranted.

As noted above, this proceeding remains open. The Wireless Competition Bureau only temporarily suspended the deadline for replies. I will provide further updates on this dispute as developments warrant.

Bidding in FCC's 3.45 GHz Spectrum License Auction Nears $21 Billion

The FCC's important auction of spectrum licenses in the 3.45-3.55 GHz band commenced on October 5 of this year. As of today, the gross proceeds of the bidding stand at nearly $21 billion for this 5G-ideal mid-band spectrum. As an October 8 article in FierceWireless by Bevin Fletcher helpfully explains, "[t]he 3.45 GHz band is licensed in ten 10-megahertz blocks in each partial economic area (PEA), with a total of 4,060 licenses." However, the Commission's rules for this auction place a 40-MHz limit on the amount of spectrum than any winner can acquire and the licenses are subject to restrictions related to government agencies' shared use of the spectrum. The auction's rules included a reserve price of $14.77 billion, so by that measure FCC Auction 110 can be considered a success. The latest information about the auction is available at Mr. Sasha Javid's website. 

I briefly wrote about the 3.45 GHz band and my previous Perspectives from FSF Scholars about lower 3 GHz band spectrum in an October 4 blog post. Free State Foundation scholars will have more to say about federal spectrum policy and FCC spectrum license auctions in the very near future. 

Verizon-Amazon Backhaul Deal Could Boost Intermodal Broadband Competition

In the latest example of dynamic intermodal ISP competition, Amazon announced this week that, once the satellite network launches, its Project Kuiper satellites will provide backhaul to Verizon’s fixed and mobile wireless networks in rural areas. This news is another sign of the existence of effective competition among ISPs and the growing irrelevance of distinguishing, for regulatory purposes, among various intermodal transmission platforms.

Project Kuiper is Amazon’s $10 billion low Earth orbit (LEO) satellite network that will offer high-speed broadband with a focus on rural and remote areas. The FCC approved Amazon to operate 3,236 satellites in July 2020. While these satellites are not yet deployed, Amazon is making progress towards launch. Project Kuiper likely will be the second large LEO constellation providing broadband—SpaceX’s Starlink already has launched over 1,700 satellites in LEO and is running a beta program for 100,000 broadband customers.

Credit: James T. M. Towill

While LEO satellite broadband offerings could sport innovations of their own, such as faster airline Wi-Fi and service in remote areas like oceans, I want to focus on what the Verizon-Amazon deal means for the overall marketplace. ISPs compete vigorously in most places for customers. The FCC’s 2020 Communications Marketplace Report demonstrated the extent of this competition, showing improvements with respect to both speeds and choice among providers. Free State Foundation scholars stressed the strong evidence of intermodal competition between transmission methods in comments submitted in this proceeding. While the FCC hasn’t yet adopted this view regarding the extent of the existence of intermodal competition, the Verizon-Amazon deal is further proof that intermodal competition is reality.

We discussed the emerging potential of fixed wireless as an intermodal competitor back in 2017. That potential is now reality. There are 6.9 million fixed wireless customers as of 2020, up from 4 million in 2016. Fixed wireless service is now available to 45% of US customers. Verizon alone has 150,000 fixed wireless customers after gaining a 55,000 subscribers in Q3 2021, an enormous 58% quarterly increase. T-Mobile, also seeing opportunity in fixed wireless, announced a price cut for its plans earlier this month. And the Verizon-Amazon deal for rural backhaul will ensure Verizon’s fixed wireless service is faster, more reliable, and available in more areas.

Senior Fellow Seth Cooper previously noted the importance of LEO satellites to future broadband competition in 2018 before the FCC approved any LEO satellite constellations. In that blog, Seth focused mostly on how satellite ISPs would compete for customers. The Verizon-Amazon deal is an example of just how dynamic broadband competition can be. While Project Kuiper and other satellite ISPs will certainly compete for their own customers, their provision of backhaul services will improve competitiveness for other transmission modes as well.

That the Verizon-Amazon deal improves Verizon’s offerings is an important point, because it shows how ISPs of various sorts can cooperate to form competitive offerings. Amazon, as a new market entrant, will face steep customer acquisition costs. These acquisition costs include marketing and sales investments to make customers aware of Project Kuiper's broadband offerings and convince them that they’re the right option. Verizon, as an established ISP, has a strong advantage in this area because it’s made these investments, has past success, and has a recognizable brand.

But Verizon needs additional, expensive-to-build backhaul capacity for its networks in rural areas. Amazon has already made capacity investments by manufacturing its satellite constellation. Given these facts, the companies teamed up according to comparative advantage. So Amazon provides backhaul to a customer of one—Verizon—in exchange for revenues Amazon can later invest in building out its customer acquisition strategy. And as a result, new customers get access to Verizon services, existing customers get better Verizon service, and Project Kuiper moves closer to viability.

Market entry by LEO constellations and cooperation among ISPs to create new competitive offerings are what Free State Foundation scholars mean when we say dynamic, intermodal competition is here. The deal between Amazon’s Project Kuiper and Verizon appears to be welcome news for broadband customers. The FCC should take note.

Randolph May's Statement on President Biden's FCC Nominations

Press Release
October 26, 2021
Contact: Randolph May at 202-285-9926

Free State Foundation President Randolph May issued the following statement regarding President Biden's nominations of Jessica Rosenworcel and Gigi Sohn to FCC seats:

“I congratulate Jessica Rosenworcel upon her nomination to continue to serve as an FCC commissioner and her appointment to chair the Commission. And I congratulate Gigi Sohn on her nomination to serve as a commissioner. Gigi has participated as a speaker at many Free State Foundation events over the years, and I’ve always welcomed the opportunity for FSF to provide a platform for the presentation of her views. We always have been, and always will be, a forum that values respectful discussion and debate.

If they are confirmed by the Senate, I’m certain that Free State Foundation scholars will not always agree with Chairman Rosenworcel and Commissioner Sohn on the issues, especially with regard to proposals to maintain or impose regulation of communications and information service providers, and the media, in the absence of convincing evidence of market failure or consumer harm. In today’s marketplace environment, there should be a deregulatory rebuttable presumption. And it is important for the FCC to acknowledge that we live in an age of media abundance, not media scarcity. This too, along with the need to be cognizant of the First Amendment's free speech guarantee, suggests the need for application of a deregulatory presumption when considering media ownership regulation and regulatory proposals.

If the Commission looks to the existence or not of market failure and consumer harm as guideposts in considering regulatory issues, along with fidelity to the law, it will promote innovation and investment, and overall consumer welfare, along with the nation’s social and economic well-being. That’s the course we’ll be advocating, with respect, if the Commission is reconstituted."  

FCC Commissioners Congratulate FSF at 15th Anniversary Event

The Free State Foundation's Fifteenth Anniversary gala lunch was held at the National Press Club on October 15, 2021. A congratulatory note by FCC Commissioner Brendan Carr and the text of prepared remarks by Commissioner Nathan Simington are available on the Commission's website. Additionally, former Commissioner Michael O'Rielly posted his prepared remarks: 

Here are my @FSFthinktank’s Anniversary Event remarks. Covers 1) misguided attempt to favor “US telecom manufacturers” based on HQ location rather than defensible standard like trusted manufacturer, & 2) critical need for more midband US 5G spectrum. Congress can fix both! https://t.co/gqV4ECcnTs pic.twitter.com/rYI9fFu43c

— Mike O’Rielly (@MPORielly) October 18, 2021

Colin Powell on Speaking Freely and Faith in America

 

It is not necessary to agree with everything that Colin Powell ever said or did to acknowledge that this soldier, statesman, and trailblazer was a true American hero. While mourning his passing, I celebrate his life, which has much to teach us about America and the never-ending task of realizing the ideals expressed in our founding guideposts, the Declaration of Independence and the Constitution.

 

Last week at the celebration of the Free State Foundation's Fifteenth Anniversary, I said that our think tank's mission "is to promote, through research and educational activities, understanding of free market, free speech, limited government, and rule of law principles and to advocate laws and policies true to these principles."

 

While much will be said and written in the coming days regarding General Powell's various contributions to our country, here I want to focus on one that is particularly relevant to our present moment, when "Cancel Culture" runs rampant throughout much of American society, chilling the ability to think clearly and speak freely.

 

In May 1994, Colin Powell delivered the Commencement Address at Howard University, and I commend it to you in its entirety. At the time of his speech, Howard was embroiled in a controversy regarding its decision to allow a Black writer and member of Nation of Islam to deliver a speech containing racist and anti-Semitic statements. Here is part of what General Powell said:

 

"I believe with all my heart that Howard must continue to serve as an institution of learning excellence where freedom of speech is strongly encouraged and rigorously protected.

 

That is at the very essence and heart of a great university and there is no doubt that Howard is a great university.

 

And freedom of speech means permitting the widest range of views to be presented, however controversial those views may be.

 

The First Amendment right of free speech is intended to protect the controversial and even the outrageous word, and not just comforting platitudes, too mundane to need protection.

 

Some say that by hosting controversial speakers who shock our sensibilities, Howard is in some way promoting or endorsing that message – not at all. Howard has helped put that message in perspective while protecting their right to be heard, so the message can be exposed to the full light of day for comment and criticism."

 

Isn't it a shame that now, more than a quarter century later, so many of those in our government, businesses, media, educational institutions, and elsewhere throughout society don't understand – or have the courage to stand up for – Colin Powell's ringing endorsement of freedom of speech, and why it matters if we are to remain a free society?

 

In recent months, I've written four pieces in a series called "Thinking Clearly and Speaking Freely," to consider the impact of the Cancel Culture and what can be done about it. Consistent with that part of the Free State Foundation's mission devoted to promoting free speech, we will continue to address this subject. But, today, you need go no further than studying – and taking to heart – Colin Powell's words from his Howard University commencement address.

 

Finally, in closing, General Powell also said this to the graduating students on that day in May 1994:

 

"Above all, never lose faith in America. Its faults are yours to fix, not to curse. America is a family: There may be differences and disputes within the family, but we must not allow the family to be broken into warring factions. From the diversity of our people, let us draw strength and not seek weakness.

 

Believe in America with all your heart and soul, with all of your mind. Remember, that it remains the "last, best hope of Earth." You are its inheritors and its future is today placed in your hands."

 

Like his call to protect free speech, General Powell's call to never lose faith in America –and the American family writ large – could not be timelier today.

 

Colin Powell, RIP. 

NJ State Court Concurs: Requirement to Prorate Cable Bills Equals Preempted Rate Regulation

Last week, a New Jersey state appellate court, wisely siding with two federal district courts, held that requiring cable operators to prorate last-month bills constitutes a form of rate regulation that is preempted by federal law.

Section 623(a)(2) of the 1984 Cable Act unambiguously states that, upon a determination by the FCC that a cable operator is subject to effective competition, "the rates for the provision of cable service by such system shall not be subject to regulation." Section 636(c), meanwhile, expressly preempts any provision of law that is inconsistent with Section 623(a)(2) (as well as with Section 623(a)(1), which states that "[n]o Federal Agency or State may regulate the rates for the provision of cable service except to the extent provided under this section.").

Nevertheless, and as I wrote in an April 2021 Perspectives from FSF Scholars, "State Cable Bills Prorating Requirements Clearly Are Preempted," two states – Maine and New Jersey – have attempted to require cable operators, and cable operators alone, to charge customers for service on a per-day basis.

Fortunately, in both cases a federal district court intervened.

In March 2020, Maine passed Public Law Ch. 657, "An Act To Require a Cable System Operator To Provide a Pro Rata Credit When Service Is Cancelled by a Subscriber." It states that a cable operator "shall grant a subscriber a pro rata credit or rebate for the days of the monthly billing period after the cancellation of service if that subscriber requests cancellation of service 3 or more working days before the end of the monthly billing period."

In an October 2020 opinion, the U.S. District Court of Maine held that obligation to be "unambiguously preempted" by the 1984 Cable Act. Specifically, the court concluded that a mandate to prorate last-month bills effectively requires cable operators to bill on a per-day basis, and therefore is a form of rate regulation preempted by Section 623(a)(1) – not a consumer protection law or customer service standard for which Section 632 creates an exception to the general rule.

For additional information on that decision, please read "Maine Cable Law, Ignoring Competition, Is 'Unambiguously Preempted'," a Perspectives from FSF Scholars published later that same month.

In March 2021, the District Court of New Jersey considered a challenge by Altice to Section 14:18-3.8 of the New Jersey Board of Public Utilities' (BPU) rules, a provision that that court found to be "virtually identical" to Maine Public Law Ch. 657. In an opinion that quoted extensively from the Maine District Court's decision, it not surprisingly reached the identical conclusion.

In addition to filing suit in federal district court, Altice also appealed the cease-and-desist order issued by the New Jersey BPU to the Superior Court of New Jersey, Appellate Division. On October 15, 2021, in an unpublished opinion, that court embraced the reasoning of the New Jersey District Court (and, by extension, the Maine District Court) and invalidated the BPU's cease-and desist order.

Notably, in both of these instances the prorated billing requirement applies exclusively to cable systems. Rival Multichannel Video Programming Distributors (MVPDs), including satellite operators, telco TV providers, and "virtual" MVPDs that distribute content over the Internet, a growing category that includes YouTube TV, Sling TV, and Hulu + Live TV, are free to bill on a monthly basis – a practice that many in fact have embraced.

As such, these court decisions, at the federal and now state levels, don't merely affirm the intent of Congress. They also serve to remove arbitrary barriers that impact only one segment of the video distribution marketplace.

Given the ever-growing prominence of streaming services (Netflix, Hulu, Amazon Prime Video, Disney+, Apple TV+, HBO MAX, and countless others), it is appropriate that regulations premised upon (at best) outdated assumptions be eliminated at every opportunity.

The Videos Celebrating the Free State Foundation's Fifteenth Anniversary Are Now Available!

 

Tweet: #FSSF15Anniversary

 

Thanks to everyone who attended the Free State Foundation's Fifteenth Anniversary Gala Lunch on October 15 at the National Press Club in Washington, DC. It was a wonderful celebration of this special anniversary milestone for FSF. Importantly, it was also a celebration of our ability to gather together again, in person, with friends. The first video below, "FSF's Fifteenth Anniversary Gala Celebration," shows the entire event, beginning with the Welcome and Introduction by Free State Foundation President Randolph May and including the remarks of our in-person speakers FCC Commissioners Brendan Carr and Nathan Simington, former FCC Commissioner Michael O'Rielly, former FCC Cable Bureau Chief Deborah Lathen, and FSF Director of Communications Policy Studies and Senior Fellow Seth Cooper. The second is the Special Commemorative Video shown at the Gala Lunch.   This Special Commemorative Video includes brief remarks from Richard Wiley, Mark Fowler, William Kennard, Michael Powell, Ajit Pai, Marsha Blackburn, Cathy McMorris Rodgers, Bob Latta, Greg Walden, Tom Tauke, Henry Rivera, Harold Furchtgott-Roth, Kathleen Abernathy, Meredith Baker, Robert McDowell, Karyn Temple, Jeffrey Rosen, David Gross, Blair Levin, Daniel Lyons, Michelle Connolly, David Honig, Ken Keane, Adam Mossoff, Roslyn Layton, Rob Atkinson, Tim Brennan, Bob Branson, Chris Walker, and Christopher Yoo. Their participation in contributing to this video is greatly appreciated! * * * * * We're grateful too that C-SPAN once again covered another of our events, this time broadcasting the speaker portion of the Fifteenth Anniversary of our event. Click HERE for the C-SPAN Video.  Tweet: #FSF15Anniversary

This Friday! FSF's 15th Anniversary Celebration with Carr, Simington, O'Rielly, Lathen and More

Register Now for This Friday!

WHAT: FSF's Fifteenth Anniversary Gala Lunch Celebration   WHERE: National Press Club, Washington, DC   WHEN: Friday, October 15, 2021, 11:30 AM - 2:30 PM

The Free State Foundation invites you to join us in person to celebrate the Fifteenth Anniversary of our founding on Friday, October 15, 2021, at the National Press Club in Washington, DC. While adhering to all COVID-19 safety protocols (see note below), we are pleased to be able to hold an in-person celebration so we can share our excitement at reaching this important milestone!   Speakers include FCC Commissioners Brendan Carr and Nathan Simington, former FCC Commissioner Michael O'Rielly, and former FCC Cable Bureau Chief Deborah Lathen.   In addition to the speakers, we will be showing a special commemorative video with brief remarks by former FCC Chairmen Richard Wiley, Mark Fowler, William Kennard, Michael Powell, and Ajit Pai, and former Acting FCC Chairman and Commissioner Mignon Clyburn, along with Senator Marsha Blackburn, Congresswoman  Cathy McMorris Rodgers, Congressman Bob Latta, former Congressmen Greg Walden and Tom Tauke, former FCC Commissioners Henry Rivera, Harold Furchtgott-Roth, Kathleen Abernathy, Meredith Baker, and Robert McDowell, former Register of Copyrights Karyn Temple, former Acting Attorney General of the United States Jeffrey Rosen, former Ambassador David Gross, former Executive Director of the National Broadband Plan Blair Levin, and many other very special friends! And there will be a "blast from the past" photo montage!   As we look back with pride at the past fifteen years, we will look forward, with confidence, to the years ahead, knowing that there is much work yet to be done in the cause of advancing free market, property rights-protective, and rule of law-oriented principles and policies.   A complimentary plated lunch will be served, subject to space limitations and reservations.   IMPORTANT NOTE: Please click here to see all the COVID-19 actions the National Press Club is taking to ensure a safe environment for everyone, including requiring proof of vaccination or a negative COVID-19 test result taken within 72 hours of an event. So, to be admitted to the Club, please make sure you bring a vaccination card or a photo of it on your phone or proof of a negative COVID-19 test result taken within the last 72 hours.   Tweet: #FSF15Anniversary     REGISTER NOW FOR OCTOBER 15, 2021!     * * *   The Gala Lunch is complimentary with no payment required. But we would certainly welcome any donation you care to make in honor of this important Free State Foundation milestone and, importantly, to help sustain our work going forward!