28 09, 2015

JSI Files Joint Comments with NTCA & WTA on Lifeline Reform Petitions of Reconsideration

2015-09-30T14:41:11-04:00September 28, 2015|Filings|

On September 28, 2015, JSI filed joint comments with NTCA–The Rural Broadband Association and WTA – Advocates for Rural Broadband in support of the Wireless ETC Petitioners Petition for Reconsideration regarding the FCC’s Lifeline Reform Order. The joint comments agree with the Wireless ETC Petitioners’ and Total Call Mobile, Inc.’s assertions that the FCC’s proposed Snapshot Rule would force ETCs to “incur costs and provide service without reimbursement.”

JSI, NTCA and WTA pointed out that RLECs typically bill all of their customers on a monthly basis, including Lifeline customers. In addition to potentially not being reimbursed monthly for “each qualifying low-income consumer served,” the proposed Snapshot Rule would require companies that bill their Lifeline customers on a monthly basis to either undergo costly billing system changes or implement a labor-intensive manual process which would increase the risk of errors and unduly complicate reporting and audits procedures.

Moreover, these changes will be necessary to accommodate what appears to be an interim measure, as the FCC has begun a proceeding for more permanent changes to the provider reimbursement process.

Thus, NTCA, WTA, and JSI requested that billing carriers be given the option of taking a snapshot of the number of subscribers as of their carrier-specific billing dates.

17 07, 2015

JSI Files Objection to Disclosure of Confidential and Highly Confidential Special Access Data and Information

2017-05-19T10:09:47-04:00July 17, 2015|Filings|

JSI, on behalf of its clients who filed full responses to the Special Access Data Collection (SPADC) in January and February 2015, filed an objection to disclosure of confidential and highly confidential data and information.

The letter pointed out that information these companies provided in the SPADC is extremely sensitive and could reveal competitive and customer information simply by the fact that they are, in many cases, the only competitive provider in their service areas.

21 05, 2015

JSI Files Comments Regarding the LNPA Transition Oversight Plan

2017-05-19T10:09:48-04:00May 21, 2015|Filings|

JSI submitted comments in response to the Federal Communications Commission’s (FCC) May 7, 2015 Public Notice seeking comment on the North American Portability Management LLC’s Transition Oversight Plan for the next local number portability administrator (LNPA). As part of the LNPA vendor transition from Neustar, Inc. (Neustar) to Telcordia Technologies d/b/a iconectiv (Telcordia), JSI would like to ensure that certain aspects of this transition have been addressed from a rural telecom perspective. Our three areas of concern are: project management, connectivity and accessibility, and cost.

JSI urged the North American Portability Management LLC, (NAPM, LLC) the North American Numbering Council (NANC) and the Transition Oversight Manager to reach out and involve rural service providers and their industry representatives in planning transition requirements, schedules and testing appropriate to their needs in order to ensure that the transition is as smooth and efficient as possible for those carriers.

13 04, 2015

JSI Submits Reply Comments on CAF Phase II Letters of Credit Requirement

2015-09-01T03:10:58-04:00April 13, 2015|Filings|

JSI submitted reply comments in response to the Wireline Competition Bureau’s February 4, 2015 Public Notice seeking comment more generally on bank eligibility requirements for the Connect America Fund (CAF) Phase II competitive bidding process.

One of the more concerning and daunting elements of the CAF Phase II competitive bidding process for small providers, as proposed, is the irrevocable Letter of Credit (LOC) requirements if they are similar to those in the Rural Broadband Experiments (RBE). JSI is well-situated to provide input on the CAF Phase II competitive bidding requirements; it assisted rural communications providers with the RBEs, some of which have been provisionally-selected entities that have completed a lengthy and resource-intensive process of obtaining LOC commitment letters and await the next step of finalizing and submitting their LOCs to the Federal Communications Commission (FCC). As such, JSI hereby provides the following reply comments on bank eligibility and LOC issues with the CAF Phase II competitive bidding process as well as lends support for previously-filed comments by USTelecom, CoBank and NTCA – The Rural Broadband Association.

8 09, 2014

JSI Files Reply Comments on Federal USF, Competitive Overlap Policies

2015-09-01T05:30:08-04:00September 8, 2014|Filings|

JSI filed reply comments in support of several proposals raised in the Federal Communications Commission’s Further Notice of Proposed Rulemaking released June 10, 2014. While many issues are addressed in this FNPRM, JSI limits its reply comments to three areas critical to the ongoing development of federal universal service policy for rural rate-of-return incumbent local exchange carriers (RLECs):

  1. Jointly Served Census Blocks: The Commission needs to examine its census block assignment for rural carriers to address jointly served census blocks for RLECs.
  2. Partially Served Census Blocks: The Commission should revisit its proposals addressing partially served census blocks.
  3. Qualification of Competitive Service Provider

JSI recommends the Commission refine its approach for jointly served census blocks, partially served census blocks, and the qualifications of competitive service providers for areas served by RLECs. Since geographic judgments will need to be fact based, the Commission needs to revisit the data it collects from competitive service providers and should rely on state commissions who are better able to judge state-specific facts.

31 03, 2014

JSI Advocates that Telephone Providers Continue to Issue Telephone Numbers

2017-05-19T10:09:50-04:00March 31, 2014|Filings|

During a Numbering Testbed Workshop at the FCC on Tuesday, March 25, 2014, JSI shared its perspective that service providers should remain responsible for assigning numbers to their customers and not allow consumers direct access to telephone numbers as the Neustar proposal asserts.

As the future of numbering in an all-IP network anticipates a consumer to use their telephone number for multiple purposes, the industry will need to ensure that the consumer’s best interests are protected and secured. Allowing consumers direct access to telephone numbers, the industry places an undue burden on the consumer to properly educate themselves on the necessary steps for securing their own telephone numbers. Service providers are more acquainted with industry practices and standards and are in a better position to provide these services to consumers, thus providing their customers with assurances that their TNs are properly secured.

Read the ex parte.

31 03, 2014

JSI & HCLS Clients File Reply Comments on Establishment of Urban Rate Floor

2015-09-01T05:37:12-04:00March 31, 2014|Filings|

JSI and its HCLS Clients respectfully request the Wireline Competition Bureau (“WCB”) or the Federal Communications Commission (“Commission”) declare the local urban rate survey to be incomplete and suspend indefinitely any increases to local rates that are tied to receiving HCLS.

The Commission needs time to revisit its policies due to the fact that its prior policies were based on faulty presumptions. The Commission anticipated that the urban rate floor would be set at a figure close to the sum of $15.62 plus state regulated fees. Based on this presumption, the Commission adopted the urban average to be the rate floor instead of a statistically valid range of confidence below the urban average. In light of the WCB survey results, this policy needs to be revisited to ensure there is a range of reasonableness around the urban average.

The WCB needs to revisit its survey methodology to ensure that it captures comparable services in urban areas with a statistically valid sample. Its evaluation of comparable services must reflect the value customers place on local services, including the value of local calling scopes in rural areas relative to urban areas. Additionally, the comparison of VoIP local service to circuit switched local service is inapposite because VoIP local service generally is fully featured whereas including these same features for circuit switched service requires additional charges. The survey also needs to verify that it is meeting the purpose of the Commission—to compare what customers pay for local service and not simply what providers offer in the urban marketplace.

In releasing its survey, the WCB failed to assess the impact of its survey results on rural customers. New evidence from the Commission reveals that it is sensitive to the fact that rural areas have been home to a disproportionate number of low-income Americans. At minimum, the WCB should assess the impact of a 40 plus percent rate increase directed at these Americans.

These considerations support the indefinite suspension of an increase of the local urban rate floor and a reexamination of the urban rate floor policy instead of a postponement of the urban rate floor as proposed by the Petitioners.

Download the comments.

31 03, 2014

JSI Comments on Rural Broadband Experiments

2017-05-19T10:09:50-04:00March 31, 2014|Filings|

JSI’s comments provide recommendations on the FCC’s intentions to conduct targeted funding experiments in both price cap and rate-of-return areas to bring advanced services to rural areas of the nation using next generation networks that are high-speed, scalable, IP-based and robust.

  • First, JSI recommends that the FCC establish a budget for the experiments of $200 million based on the significant amount of letters received (over 1,000) and large demand for support that would encourage network investment. Committing $200 million would go far to satisfy the demand, select a wide range of experiments, and allow the Commission to retain at least $30 million unallocated in its reserve.
  • Second, JSI argues that the Commission’s precondition that the only areas eligible for funding should be those areas lacking broadband is too narrow and restrictive. The experiments should address how to future-proof wireline networks with fiber facilities in the delivery of broadband that is high-speed, scalable and robust.
  • Third, JSI addresses the issue of ETC designation and explains that the FCC’s proposed approach creates an unresolvable problem for state commissions.
  • Fourth, JSI recommends that RLEC applications be evaluated and qualifying applicants be awarded prior to applications from other providers, subject to a challenge process.
  • Finally, JSI comments on the selection criteria for the experiments, and makes several recommendations for evaluating applications based on robust, scalable networks.

See Comments Here

24 03, 2014

JSI Submits Number Management Proposal to FCC

2017-05-19T10:09:50-04:00March 24, 2014|Filings|

In an ex parte to the FCC, JSI filed its number management in an all-IP network proposal. The proposal addresses the architecture of the number administration databases and inventories in an all IP network.

JSI envisions a number management structure that will allow the service provider to maintain responsibility for its numbering resources – telephone numbers, IP addresses and security credentials – and assign them to customers upon requests. Additionally, the proposal asserts that number management in the future all-IP arena should be simple, reliable, effective and allow service providers to maintain the core services they are expected to provide to customers on a daily basis – quality service, immediate telephone number assignment and seamless porting.

Read the ex parte.

20 02, 2014

JSI Proposes Hundreds-Block Pooling (HBP) for the FCC’s Numbering Testbed

2015-09-01T05:41:51-04:00February 20, 2014|Filings|

JSI believes that testing and possibly transitioning to the hundreds block pooling system would be a much more cost effective and time-saving number allocation process for both service providers and the industry as a whole. The hundreds block level assignment will allow service providers to maintain a numbering inventory, which is essential for customer service. Hundreds-block pooling will also provide service providers with a minimal impacting option to the current numbering process, which will allow for more focus and resources on the IP transition. For these reasons, JSI is advocating that hundreds-block pooling be part of the numbering testbed.

See Full Ex Parte

Go to Top