Raymond A. Kowalski

Ray is a senior telecommunications advisor who assists the firm’s attorneys and clients in matters relating to FCC regulation, including license assignments and transfers, equipment authorization, regulatory compliance, and spectrum policy. His career has spanned more than 50 years, including 19 years of experience with the FCC.

Ray’s practice has focused on clients affected by telecommunications regulation, whether or not they are engaged in the commercial provision of telecommunications services. These include clients who use licensed or unlicensed communications facilities such as land mobile dispatch systems, internal point-to-point microwave systems, point-to-multipoint microwave systems, and aviation and maritime communication systems. Such clients include electric utilities and companies that manufacture, import, or market devices containing digital circuitry that are subject to FCC equipment authorization requirements.

In most cases, Ray’s practice has involved assisting clients in obtaining FCC licenses, obtaining rule waivers for unique operations, or obtaining FCC consent for transactions to purchase or sell spectrum or licensed facilities. In some cases, Ray has assisted clients in responding to FCC enforcement actions.

Ray has represented electric utilities in pole attachment negotiations; municipalities in developing cable TV franchising agreements or local ordinances; and public safety entities and other organizations in defending their spectrum allocations.

FCC Experience

Before leaving the FCC in 1988 to enter private law practice, Ray was in training for the Government’s Senior Executive Service. He was chief, Special Services Division, of the Private Radio Bureau (now the Wireless Bureau). Ray was also a trial attorney in the Broadcast Bureau (today, the Media Bureau); head of the Compliance Division of the Private Radio Bureau; and responsible for the regulation of aviation, maritime, and personal radio services. He participated in U.S. delegations to the International Maritime Organization (IMO) and to the Inter-American Telecommunication Commission (CITEL).

• Represented investor-owned electric utilities in the defense of pole attachment complaints before the FCC and in the U.S. Court of Appeals.
• Drafted and negotiated pole attachment agreements with cable television companies and competitive local exchange carriers.
• Represented a large electric distribution cooperative from the business plan phase through execution of the bidding strategy in obtaining FCC licenses in the auction of spectrum in the 220 MHz band.
• Monitored legislative and regulatory developments and assisted clients in responding through testimony before Congressional committees or comments in agency proceedings.
• Negotiated spectrum relocation agreements with wireless PCS providers on behalf of a transcontinental pipeline company, an investor-owned utility, and several other municipal and industrial licensees of private microwave facilities.
• Counsel to several electric utilities regarding the use of rights of way to carry broadband, fiber optic cable.
• Counsel to municipalities for review of cable television franchise agreements, local ordinances relating to rights of way, and telecommunications franchises.
• Counsel to manufacturers of microwave communications equipment, automated meter reading equipment, telephone network equipment, and other manufacturers of radio frequency equipment regarding federal equipment authorization, importation, and marketing requirements.

• Rated AV Preeminent by Martindale-Hubbell® (2025)
• Named a Top Rated Lawyer in Technology law by The American Lawyer and Corporate Counsel magazine (2012)
• Recipient of the Eugene C. Bowler Award for career excellence in the telecommunications field, awarded by the National Association of Business and Educational Radio (NABER), 1987