On June 9 the Federal Communications Commission (FCC) took another step on its path to streamline local government review of wireless technology siting by adopting its 5G Upgrade Order i which further refines and clarifies its previous rulings related to Section 6409(a) of the Middle Class Tax Relief and Job Creation Act of 2012 (TRA) ii . Section 6409(a) was enacted to expedite State and local government review of requests to modify existing wireless communications facilities. Section 6409(a) provides that "a State or local government may not deny, and shall approve, any eligible facilities request for a modification of an existing wireless tower or base ...