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.