On October 19, 2015, JSI filed joint reply comments with NTCA–The Rural Broadband Association and WTA – Advocates for Rural Broadband in reply to those who opposed CTIA—The Wireless Association’s Petition for Reconsideration regarding the FCC’s Lifeline Reform Order.

JSI and the rural associations agree with CTIA’s petition that the document retention rules recently adopted in the FCC’s Lifeline proceeding exceed the Commission’s authority under Sections 222 and 201(b) of the Communications Act and that the FCC should reconsider these document retention rules.