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So far Robert Williams has created 24 blog entries.

Upcoming Filing Deadline Reminders: Service Accessibility Compliance Certification and FCC Section 254(g) Certification

2022-03-30T09:25:12-04:00March 30, 2022|e-Lerts|

JSI reminds clients of two upcoming deadlines: (1) service accessibility compliance certifications (April 1, 2022) and (2) FCC Section 254(g) interexchange rate integration and rate averaging certification (May 1, 2022). Details are provided below.

Service Accessibility Compliance Certification

Telecommunications service providers have until April 1, 2022, to submit their certifications for the calendar year 2021 to the FCC regarding the accessibility of services for people with disabilities. The filing must be completed using the FCC’s Recordkeeping and Compliance Certification and Contact Information Registry at https://apps.fcc.gov/rccci-registry/. Specifically, providers must certify that they have established operating procedures to:

  • Document efforts to consult with individuals with disabilities;
  • Document the accessibility features of products and services; and
  • Record information about the compatibility of such products and services with peripheral devices or specialized customer premise equipment commonly used by individuals with disabilities to achieve access.

The FCC requires each company, and their affiliates that provide telecom services, to file the certifications. If previously submitted contact information remains current, the 2022 submission need only include the new compliance certification. Any updates to contact information must be made using the online registry within 30 days of the change.

FCC Section 254(g) Interexchange Rate Integration and Rate Averaging Certification

Each non-dominant provider of detariffed interstate interexchange service must certify by May 1, 2022, that it provides service in compliance with the geographic rate average and rate integration obligations pursuant to section 254(g) of the Communications Act. Geographic rate averaging prohibits a company from charging different rates for calls of similar geographic scope. Providers must certify annually that pricing policies are not discriminatory among rural and high-cost areas and that rates charged in each state are no higher than rates charged to any other state.

Clients who need assistance with either of these filings should contact Kim Waldvogel in our Maryland office at 301-459-7590 or via email by using the button below.

Wisconsin Broadband Expansion Grant Program: Objection Period Now Open

2022-03-28T17:58:58-04:00March 28, 2022|e-Lerts|

JSI Encourages Wisconsin Clients to Check Proposed Project Areas in Recently Filed Applications and Confirm Whether There Is Any Overlap

The Public Service Commission of Wisconsin (PSC) opened the window to object to grant applications filed under the Broadband Expansion Grant Program. Interested parties must file their comments opposing an application on or before April 14, 2022, at 4:00 pm (CT) using the PSC’s electronic filing system under Docket 5-BF-2022. Providers should address such objections to the Secretary to the Commission, Public Service Commission of Wisconsin.

Objectors should be prepared to demonstrate why the PSC should reject the application. Commenters should focus on deficiencies in the application, such as factual inaccuracies, ineligibility, or why the grant funds would be better spent elsewhere.

Grant applicants facing an objection have until April 21, 2022, at 4:00 pm (CT) to submit a response.

If you would like assistance submitting an objection, responding to an objection filed against your grant application, or have a question about this process, please click the button below to connect with one of our experts.

Cybersecurity Warning

2022-03-23T17:56:34-04:00March 22, 2022|e-Lerts|

Critical Infrastructure Organizations Should Bolster Their Cyber Defenses

On March 21, President Biden released a statement on the importance of continued vigilance in protecting US critical infrastructure, stressing the need for strong cybersecurity controls. This statement follows the Russian invasion of Ukraine, US-led sanctions, and new reporting requirements for critical infrastructure companies, which include broadband providers. The new requirements are contained in the Strengthening American Cybersecurity Act, which mandates critical infrastructure companies report certain computer security incidents to the Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (CISA) within 72 hours of discovery and even faster, within 24 hours, if payment is made for ransomware.

The statement and associated fact sheet advise that critical infrastructure companies should immediately take the following steps to harden their defenses:

  1. Implement multi-factor authentication (MFA) for remote access and on all exposed systems to prevent unauthorized access (note that the standard use of username/password is not sufficient protection).
  2. Ensure data is backed up and encrypted. Additionally, backups should be tested for recovery and separated from the rest of the network to guard against ransomware.
  3. Develop an incident response plan that includes reporting guidelines and considers these four recommendations from the NIST Computer Security Incident Handling Guide:
    a. Preparation;
    b. Detection and analysis;
    c. Containment, eradication, and recovery; and
    d. Post-incident activity.
  4. Educate and test employees on security awareness on a variety of topics and ensure they take part in business continuity and incident response exercises, so they are prepared when an incident occurs.
  5. Assess systems and processes using modern tools and mitigate discovered vulnerabilities via patching or system hardening.
  6. Implement network monitoring and logging to detect attacks and prevent a major incident from occurring.

For questions concerning this or any other cybersecurity issue, please press the button below to connect with one of our subject-matter experts.

ReConnect Challenge Process Begins: Are You Prepared to Defend Your Service Area?

2022-03-18T19:24:40-04:00March 18, 2022|e-Lerts|

JSI Encourages All Providers to Determine If Their Service Areas Are Impacted by the Proposed Service Areas in Applications

This week, the USDA released three public notices listing 288 applications that have been filed under the ReConnect III program. These announcements open a 45-day window for existing service providers to challenge the validity of the funded service areas proposed by ReConnect applicants that overlap with your company’s existing service area. If a ReConnect application’s proposed service area overlaps with your service area, and you can show that you are providing broadband speeds of at least 100/20 Mbps, your challenge could be successful. This brief window is now open and will close on April 28, 29, or 30, 2022, depending on the release date of the public notice announcing the application.

USDA is issuing these announcements daily, so keep checking to see if any of the applications propose overlapping service. More information on these applications can be found here. To depict the extent of the overlap between the current service provided and the proposed funded service areas (PFSAs) under the ReConnect program, JSI has created maps for all the applications announced to date. As additional public notices are released, we will continue to review the data to help companies determine the extent of any overlap.

If an application impacts your service area, and you would like to challenge that application, the USDA requires the following:

  1. A shapefile of the area in which you already provide broadband service of 100/20 Mbps.
  2. Additional information such as your company’s contact information, the technology used to provide broadband service, the type of service provided, the highest download and upload speeds available in the PFSA, and the number of households capable of and currently receiving broadband service of at least 100/20 Mbps in the PFSA you are challenging.

For more information on the process and instructions on how to submit a challenge, click here.

If you need assistance with developing your response to defend your area and for more information about the extent of the overlap and how it impacts your area, please click the button below to connect with one of our experts.

Important New Developments in National Broadband Mapping

2022-03-04T10:49:15-05:00March 4, 2022|e-Lerts|

Broadband Service Providers Should Get Ready to Upload Data This Summer

The Infrastructure Investment and Jobs Act (IIJA) directs the Federal Communications Commission (FCC) to improve broadband mapping accuracy prior to the disbursement of most of the $42 billion Broadband Equity, Access, and Deployment (BEAD) grant program. In our February 28 e-Lert, we informed clients that the FCC had announced that fixed and mobile broadband providers must input their broadband availability data into the Broadband Data Collection (BDC) platform during the filing window that begins on June 30, 2022, and ends on September 1, 2022. The submitted data must reflect broadband availability as of June 30, 2022. The FCC has not yet finalized its detailed data specifications that will instruct providers on how to prepare and format their BDC data submission.

Importantly, the BDC data submission does not replace the FCC’s Form 477 data submission. Providers will be required to upload data into the BDC system—using the yet to be announced FCC specifications—in addition to uploading their Form 477 data.

One critical component to the FCC’s BDC mapping effort was the selection of a Broadband Serviceable Location Fabric (BSLF) contractor. The BSLF forms the mapping structure for the BDC platform and contains the broadband location data used to support the BDC program. The FCC received bids for this work and awarded the contract to CostQuest Associates (CostQuest). Another bidding entity challenged the FCC’s award, thereby suspending the contract award until the GAO reviewed the bidder’s protest. On February 24, the GAO denied the losing bidder’s protest, and the contract was officially awarded to CostQuest.

That GAO action clears the way for the BDC platform to be finalized. And providers will input their broadband availably data this summer. Notably, the FCC may open the BDC input window earlier than June 30 if the system is ready. The next action related to BDC input is for the FCC to deliver data submission instructions to providers so that provider data can be formatted for BDC input.

The FCC understands that the BDC mapping results are critical for BEAD grants, and JSI expects it will make the BDC data specifications instructions available as soon as possible, thereby giving providers sufficient time to meet the September 1 deadline.

If you have any questions about the BDC or how JSI can help you with the BDC input process, please click the button below to connect with one of our experts.

FCC Seeks Comments on Rural Health Care Program, Communications Accessibility, and Universal Service Fund

2022-03-03T15:08:51-05:00March 3, 2022|e-Lerts|

Clients have several opportunities to provide feedback and insight to help the Federal Communications Commission (FCC) shape policy and inform upcoming congressional reports. JSI encourages clients to file comments in proceedings relevant to their business and share company-specific perspectives.

Rural Health Care Program

The FCC is proposing new rules and seeks comment on changes to the Telecommunications (Telecom) Program, a component of the Rural Health Care (RHC) Program. The Telecom Program ensures that rural health care providers do not pay more than their urban counterparts for telecommunications services by subsidizing the difference between rural and urban rates.

The FCC seeks comment on how to improve the accuracy of support provided by the Telecom Program and decrease administrative burdens. Clients that provide services to rural healthcare providers and receive support from the Telecom Program are encouraged to submit comments in response to the FCC’s proposals and inquiries. Although not yet published in the Federal Register, comments will be due 30 days after the FCC order is published.

Accessibility of Communications Technologies

The FCC also invites comment on issues relating to communications accessibility and plans to use such comments to inform its biennial report to Congress, which is required by the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA). The CVAA requires telecommunications, interconnected voice over Internet protocol (VoIP), and advanced communications service providers and equipment manufacturers to make their services and equipment available to and useable by people with disabilities. The CVAA also requires Internet browsers on mobile phones to be accessible to and usable by people who are visually impaired.

The FCC seeks comment on current levels of compliance with the CVAA, products or services that are not accessible, and the extent to which providers and manufacturers ensure the usability of their offerings through accessible manuals, bills, and product support. The FCC also seeks comment on developments in the accessibility of new communications technologies such as 5G, high-definition (HD) voice, the Internet of Things, and Bluetooth.

In light of the COVID-19 pandemic, the FCC is especially interested in whether equipment necessary to work, study, and obtain healthcare remotely is accessible to people with disabilities. The deadline for filing comments in this proceeding is April 4, 2022.

The Future of USF

JSI recently filed comments in response to the FCC’s Notice of Inquiry on the future of the Universal Service Fund (USF). JSI encouraged the FCC to adopt a policy framework that secures the future of needed federal high-cost universal service. JSI also encouraged the FCC to recognize and report to Congress the historic importance of the federal high-cost universal service programs. JSI emphasized that the programs provide crucial support to rural local exchange carriers who provide broadband services to rural customers in furtherance of the FCC’s goal to ensure all Americans have access to quality broadband. JSI also recommended the FCC adopt robust standards for universal service and further universal service in high-cost areas of the nation by:

  • Coordinating the use of grant funds with existing high-cost universal service support;
  • Reinforcing the importance of the Eligible Telecommunications Carrier designation for providers seeking universal service;
  • Requiring trained auditors to conduct reviews for waste, fraud, and abuse in high-cost programs;
  • Revisiting the distribution of the remaining Rural Development Opportunity Fund budget to better address deployment needs in rural areas;
  • Ensuring levels of universal service support to construct and maintain rural networks; and
  • Engaging in meaningful universal service contribution reform in 2022.

In response to its inquiry, the FCC received 75 comments. Of particular interest to the rural providers JSI serves, many commenters discussed funding USF with Congressional appropriations instead of contribution charges, reforming high-cost USF, and maintaining USF for operating expenditures. JSI plans to file reply comments addressing these issues and encourages clients to file company-specific comments in which they can provide their own perspectives on proposals made by commenters.

JSI’s seasoned advocacy experts are ready to provide strategic advice and assist in drafting company-specific comments. Reply comments are due on March 17, 2022, so we ask that clients interested in JSI’s help contact us no later than March 10, 2022.

If you would like JSI’s help with writing comments or are otherwise interested in discussing any of the topics raised in this e-Lert, just click below, and one of our FCC experts will contact you.

FCC Announces Filing Deadline for New Broadband Data Collection and Adds $86 Million to the Emergency Connectivity Fund

2022-03-01T18:49:00-05:00February 28, 2022|e-Lerts|

The FCC recently made two announcements impacting broadband providers’ reporting obligations and participants in the Schools and Libraries program. First, fixed and mobile broadband service providers must submit broadband availability data in the FCC’s Broadband Data Collection (BDC) system between June 30 and September 1, 2022, as required by the Broadband Deployment Accuracy and Technological Availability (DATA) Act. Second, the FCC bolstered its Emergency Connectivity Fund (ECF) and extended the deadline for beneficiaries to spend support payments.

The BDC’s biannual collection and dissemination of granular data applies to terrestrial fixed, fixed wireless, satellite, and mobile broadband internet access services. Although the FCC has established these filing dates now, it has yet to finalize the details. The FCC plans to make further announcements that instruct filers on how to prepare and format their BDC availability data. Instructions will address the types of data filers must submit, the proper file formats for upload, and the values that the system will accept and validate against other sources. The FCC may also move up or delay the filing window, depending on the progress of other parts of the BDC system, although any modifications must give filers at least 60 days’ notice. JSI will provide an update as soon as new information becomes available.

Meanwhile, until the FCC announces a sunset date, broadband service providers must continue to file broadband and voice subscribership deployment data using the Form 477 filing interface. Until the FCC decommissions that system, providers must submit such information in both the new BDC system and the existing Form 477 filing system. Voice-only service providers, however, need not submit their subscribership data in both systems and will instead continue to use the Form 477 filing interface.

Additional information can be found on the BDC website at https://www.fcc.gov/BroadbandData/.

On the ECF front, the FCC committed another $86 million in Emergency Connectivity Funding to support students and libraries and to help close the homework gap. Since it began in June of 2021, the ECF program has committed over $4.6 billion to support more than 12 million students and over 900 libraries. This latest infusion will provide over 350 schools, 29 libraries, and 8 consortia with over 239,000 connected devices and over 96,000 broadband connections.

In addition, the FCC’s Wireline Competition Bureau extended the date by which beneficiaries must use the funding to June 30, 2023. This one-year extension establishes a new deadline for ECF beneficiaries to request equipment, other non-recurring services, and recurring services submitted during the first and second ECF Program application-filing windows (the first one closed on August 13, 2021, and the second on October 13, 2021). Program beneficiaries can use the funding to support off-campus learning, such as nightly homework, to ensure students have the necessary support to keep up with their education.

If you would like JSI’s help with any FCC requirements or filings or have any questions about the information contained in this e-Lert, just click the button below to connect with a member of our team.

FCC Takes Another Look at Individual TN Pooling

2022-02-25T18:18:14-05:00February 25, 2022|e-Lerts|

Three state utility commissions have asked the FCC once again to consider individual telephone number pooling (ITN pooling) as a proposed method of conserving numbering resources within an area code. The process involves a numbering administrator assigning telephone numbering resources one telephone number at a time, rather than at the current pooling level blocks of 1,000 numbers. The industry previously studied the feasibility of ITN pooling in 2000 but the idea did not reach fruition.

Maine, New Hampshire, and North Dakota have requested that the FCC revisit the idea’s technical, operational, and cost requirements to implement individual telephone number pooling on a trial basis. Advocates of the trials believe ITN pooling may offer more efficient number assignments and help to avoid premature area code exhaustion.

Which States Want ITN?

  • Maine Public Utility Commission filed a petition asking the FCC to direct the NANPA to report on the requirements to implement individual telephone number pooling for the 207 area code on a trial basis.
  • New Hampshire Public Utilities Commission filed a petition to implement a trial for individual telephone number pooling in NPA 603.The NH PUC also supported the Maine petition.
  • The North Dakota Public Service Commission DPSC supported the Maine and New Hampshire petitions and asked the FCC to grant it the same relief to implement ITN pooling for its 701 area code.
  • The Massachusetts Department of Telecommunications and Cable filed comments supporting New Hampshire’s petition for the 603 area code but did not request its own ITN trial.

Next Steps

In response to the requests, the FCC has directed the North American Numbering Council (NANC), through its Numbering Administration Oversight Working Group (NAOWG) to investigate the feasibility of ITN pooling trials, including technical, operational, and cost considerations with respect to the entity administering the pooling (such as the Pooling Administrator), service providers, and other stakeholders. The FCC also asked to NANC for suggestions for alternatives to ITN. The NANC must submit a report to the FCC by August 15, 2022.

JSI’s Bridget Alexander White serves as Vice Chairwoman of the NANC and will be working on this report as part of the NANC’s NAOWG. Service providers in the applicable states are invited to share opinions with Bridget – good, bad, or ugly – on the proposed ITN trial. She can be reached via email or at 301-459-7590.

Numbering & Porting Essentials Service

Clients interested in educating their staff on the cavalcade of numbering, porting and robocall mitigation requirements all service providers will face in 2022 should consider subscribing to JSI’s Numbering & Porting Essentials service. The subscription includes breaking news alerts, a free webinar and web-based education sessions designed to keep companies informed about important numbering, porting and robocall mitigation decisions that will impact their internal operations and customers. Contact Bridget Alexander White for more details and to sign up.

Entry-Level Accounting Analyst – Maryland HQ

2022-03-10T12:11:52-05:00February 23, 2022|Career Opportunities|

Founded in 1962, JSI is a full-service consulting firm and broadband solutions leader providing a complete range of financial, regulatory, engineering, and management assistance to independent, community-based communications providers across the United States. JSI provides critical consulting services to broadband service providers who are an integral part of today’s national initiative to close the digital divide in our country. This is a unique opportunity to be a part of something very special.

JSI is seeking recent college graduate for an entry-level position.


• Candidate should possess a college degree in Accounting, Business, or related field.

• Must have strong communication skills.

• Solid Microsoft Excel skills including proficiency with pivot tables, formulas, and macros. Attention to detail is a must.

• Successful applicant must possess the desire and ability to learn, contribute and grow in this dynamic industry and firm.

We offer a competitive salary and benefits package, along with a casual and stimulating work environment. Excellent growth potential. Visit our website at www.jsitel.com. Please send a copy of your current resume and salary requirements to BDickerson@JSITel.com.

Territory Account Manager – Remote

2022-03-16T17:02:17-04:00February 16, 2022|Career Opportunities|

Founded in 1962, JSI is a full-service consulting firm and broadband solutions leader providing a complete range of financial, regulatory, engineering, and management assistance to independent, community-based communications providers across the United States. JSI provides critical consulting services to broadband service providers who are an integral part of today’s national initiative to close the digital divide in our country. This is a unique opportunity to be a part of something very special.

JSI is seeking to hire an ambitious Territory Account Manager. The Account Manager will:

  • Develop strong, ongoing relationships with prospects and customers
  • Prospect and qualify new sales leads
  • Go deep and wide within the account
  • Nurture and cross-sell existing client base
  • Create, plan, and deliver presentations on company products
  • Communicate customer and prospect product pain points to appropriate departments
  • Maintain a well-developed pipeline of prospects
  • Be able to work JSI Booth at trade shows and seminars
  • Service customer by selling services that solve customer issues
  • Coordinate with other team members and departments to optimize the sales effort
  • Knowledge of Telecommunications or Information Technology industries preferred
  • Understanding of Network Engineering concepts, NOC services or DDoS services a plus


  • Bachelor’s degree in Business, Marketing, Communications, Engineering, or related field
  • 1-2 years of sales experience in the field or Inside Sales
  • Proven ability to meet and exceed sales quotas
  • Proven track record of successfully managing customer relationships
  • Excellent interpersonal skills
  • Highly self-motivated
  • Strong verbal and written communication skills
  • Travel up to 50%

This is an exciting time to be in the telecom business and we are looking for new talent who bring innovative ideas and skillsets to help our clients. Our diverse staff includes accountants, financial experts, lawyers, engineers, writers, entrepreneurs, MBAs, program leaders, and project managers.

JSI is growing and expanding into new lines of business and we want you to be a part of our future. It does not matter whether you are just starting your career or you are a seasoned telecom veteran, if you are passionate about contributing your skills, knowledge, and experience to have a direct impact on the business, we want to talk to you. Please email your resume to BDickerson@JSITel.com.

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