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.

Webinar: Breaking Down the ReConnect Round 3 Funding Program

2021-11-12T08:29:17-05:00November 11, 2021|Webinar Recordings|

The U.S. Department of Agriculture’s (USDA) Rural Utilities Service (RUS) has announced the application window for Round 3 of its Rural eConnectivity Program (ReConnect), which will provide $1.15 billion in grants, loans, and grant-loan combinations for broadband buildout projects in rural America. This third round of funding will consider areas where 90% of the households lack access to fixed broadband services with speeds of at least 100/20 Mbps. If you did not have qualifying areas for Round 2, you likely will for Round 3 due to this eligibility change. The program requires awardees to provide services with speeds of 100/100 Mbps to all premises in the proposed geographic area(s). RUS will begin accepting applications on November 24, 2021, and all applications must be received by February 22, 2022.

JSI recently hosted a webinar to help those interested in applying for the funds prepare for the 2022 program. Our experts, who have shepherded many companies through the process in Rounds 1 and 2, shared important information and strategies, including:

  • Program requirements and deadlines for grants, loans, and grant/loan combinations, including details on requirements for tribal governments and socially vulnerable communities
  • Differences between Round 3 and previous competitions
  • How to determine eligible areas and whether to apply
  • Details on RUS’s scoring criteria
  • Strategies for success based on JSI’s work with past ReConnect winners

Because of the program’s complexity and the funding options available, this webinar also will feature scenarios for each of the funding options: 100% loan, 50% loan 50% grant combinations, 100% grant, and 100% grant for tribal governments and socially vulnerable communities.

JSI-assisted applicants have been very successful in previous ReConnect competitions, with 93% of Round 2 applicants awarded funding through the program. We are ready to work with you on all aspects of a ReConnect application and broadband project.

For a copy of the webinar recording, please contact Brenda Cordwell at 240-556-1295. For more information about the ReConnect program or to get started on an application, please contact Lans Chase at 770-569-2105 or Amanda Molina at 321-985-5709.

Landmark Federal Infrastructure Bill to Provide $65 Billion for Broadband

2021-11-09T15:03:13-05:00November 9, 2021|e-Lerts|

Congress passed the Infrastructure Investment and Jobs Act late on Friday, November 5, 2021. The legislation appropriates more than $1 trillion to fund national infrastructure projects, including approximately $65 billion specifically for broadband infrastructure and related programs over the next five years. The bill now heads to the White House for signing. Rural broadband providers will benefit from several of the Act’s programs. This e-Lert summarizes the key broadband provisions for rural broadband providers.

Broadband Equity, Access, and Deployment (BEAD) Program
The National Telecommunications and information Administration (NTIA) will distribute $42.45 billion to the states based on the number of unserved locations in each state, with an initial minimum allocation of $100 million for each state. The remainder of the funds will be distributed based on each state’s unserved locations, defined as those lacking 25Mbps / 3Mbps. Private companies, cooperatives, and public-private partnerships will be eligible to receive grant funds through each state. Grants can be used for unserved (25/3Mbps) and underserved (less than 100/20Mbps) projects; connecting anchor institutions; data collection, broadband mapping and planning; installing CPE to eligible multi-family residential buildings; providing affordable internet-capable devices; and other uses determined by NTIA. Except for high-cost areas, grant funds may cover a maximum of 75% of the project costs, but grantees may use funds from the four previously passed COVID-19 response laws to meet the remaining 25%. Funded projects must deliver 100/20 Mbps within four years and must offer at least one low-cost broadband service option.

Middle-Mile Infrastructure Grant Program
Congress appropriated $1 billion to NTIA for a competitive middle-mile grant program to connect unserved and underserved last mile areas to the Internet backbone. Rural carriers are among the entities eligible for this program, which encourages public/private partnerships and may fund up to 70% of the middle-mile project costs. NTIA must release its notice of funding within the next six months.

Affordable Connectivity Program
Congress extended and modified the Emergency Broadband Benefit Program (EBBP), now called the Affordable Connectivity Program (ACP), with $14.2 billion to the FCC. The Act decreases the non-tribal monthly household benefit from $50 to $30.

ReConnect
Congress appropriated $2 billion for the fiscal year ending Sep. 30, 2022, to Rural Utilities Service’s existing the ReConnect program for broadband grants, loans and grant/loan combinations. ReConnect requires broadband speeds of at least 100/20 Mbps.

Tribal Broadband Connectivity Program
Congress appropriated $2 billion to the existing Tribal Broadband Connectivity Program for 2021-2022 fiscal year and to remain available until expended.

Appalachian Region High-Speed Broadband Deployment Initiative
Congress appropriated $1 billion over five years to the Appalachian Regional Commission for High-Speed Broadband Deployment and Regional Energy Hub initiatives. Congress directs that at least 65% of the funds be used for the broadband initiative. The Regional Commission must coordinate its grants with the FCC, NTIA, and the Economic Development Administration (EDA) to avoid duplication of federal funding programs.

Digital Equity Programs
Congress appropriated $1.5 billion over five years to promote the achievement of digital equity, support digital inclusion activities, and build capacity for efforts by states related to broadband adoption. States must develop a State Digital Equity Plan and submit it with its application for grant funds. The Commerce Department will also create the Digital Equity Competitive Grant Program to award $1.25 billion over five years to support those efforts.

Other Notable Items

Beyond the various grant programs contained in the legislation, Congress directed the FCC to take action in three broadband-related administrative programs:

  • $10 million to the FCC for a Broadband Deployment Locations Map. This program is funded separately from the FCC’s broadband DATA maps but will incorporate broadband service availability reported by those maps.
  • The FCC is directed to examine and make recommendations on how it should achieve universal service goals for broadband and submit to Congress its report in 270 days after the Act’s enactment.
  • Congress also directs the FCC to develop rules for consumer labels for broadband service no later than one year of enactment. After the FCC develops the rules, broadband providers must use broadband consumer labels when giving information to customers regarding broadband internet access service plans.

In addition, the legislation includes funds for improving the nation’s electric grid through smart grid and boost its security. The Rural and Municipal Utility Advance Cybersecurity Grant and Technical Assistance Program will provide $250 million for grants to help rural and municipal utilities deploy advanced cybersecurity technologies for electric utility systems and increase participation in threat sharing programs. As well, $3 billion will go towards a Smart Grid Investment Matching Grant Program to fund up to 50% of qualifying smart grid investments.

Please contact Douglas Meredith at 801-294-4576 or Carl Perry at 512-338-0473 if you have questions or concerns about the Infrastructure Act or would like JSI’s help in planning your participation in these new opportunities.

Webinar Duo: Broadband Funding – Where’s the Money & How to Plan for Success

2021-12-07T17:06:10-05:00June 23, 2021|Webinar Recordings|

Expanding broadband, particularly in rural America, is finally in the spotlight after the COVID-19 pandemic has shown the need for everyone to be connected. We are seeing billions of dollars being appropriated on the federal and state levels for broadband buildout and other programs to connect Americans to their work, schools, doctors, and other institutions.

This flood of money will provide many opportunities for broadband providers, but you need to keep track of these new developments and prepare for the various programs’ requirements. We recently held a two-part webinar event. During Part One we surveyed all the programs that are authorized and being planned—including state grant deployments, tribal land funds, and NTIA funding programs. Part Two focused on steps you can take today to prepare and what you need to do to be successful in receiving these funds for your deployment.

Part One:

  • Updates on several annual grant/loan programs, including RUS’s ReConnect and Community Connect;
  • How state and local governments plan to use the $220 billion provided in the COVID-19 State Fiscal Recovery Fund and $130 billion in the Coronavirus Local Fiscal Recovery Fund and what portion of those funds could be earmarked for broadband-related efforts;
  • New funding programs under the National Telecommunications and Information Administration (NTIA), including the Economic Development Appropriation and the Broadband Infrastructure Program; and
  • Other programs that may tangentially benefit broadband providers and their customers, such as the Homeowners Assistance Fund and the Emergency Connectivity Fund.

Part Two:

  • Identifying potential target areas even before an application deadline is announced;
  • Starting conversations with potential partners/allies in order to expand eligibility for grants based on the qualification of both parties;
  • Preparing business cases, buildout budgets and financial documents, including letters of support; and
  • Getting set up with required registrations (CAGE codes, Dunns numbers, state registrations, etc.) to speed up your application prep.

Recordings of the full two-part webinar are available for $400. Contact Brenda Cordwell in the Maryland office at 301-459-7590 for more information about these webinars or to purchase the recording.

Begin Prepping Now for ReConnect Round 3 Competition

2021-11-02T13:13:19-04:00April 30, 2021|e-Lerts|

We expect to see the Rural Utilities Service (RUS) announce the third competition soon for grants and loans under the U.S. Department of Agriculture’s (USDA) Rural eConnectivity Pilot Program (ReConnect). RUS could open the competition any time. RUS recently requested comments on rule and criteria changes and that comment period ended earlier this week. The standard application window has been six weeks. And unlike the recent RDOF reverse auction, ReConnect funds network construction based on the budget you provide.

Six weeks does not leave much time for identifying qualified areas, completing financials, and preparing applications. Starting some of that work now will allow you to target the best areas for your application, start a build-out budget, and collect the required documentation to develop a competitive application once the final grant rules are announced. Much of this prep work also will be applicable to other grant programs, such as special COVID-19 related programs and state grants. For example, all applications require a System for Award Management (SAM) registration to do business with a government agency, including RUS. The SAM registration provides companies with a Commercial and Government Entity Code (known as a CAGE code). These CAGE codes sometimes take several weeks for companies to obtain.

Leverage JSI’s Success and Expertise
JSI can help broadband providers with all aspects involved with completing applications. Our clients have had tremendous success in the first two rounds of ReConnect. During ReConnect Round 2 in 2020, 93% of the providers we worked with on their applications were awarded grants and loans.

Even before the competition begins, our experts can map potentially eligible unserved and underserved communities so that you target the right areas. These maps can show you competitors and their speed coverage; existing mechanisms funding the area (grants/loans, RDOF funding, RUS borrowers, etc.); and the number of locations. The maps should guide you to your target areas and can easily be fine-tuned based on the program’s final criteria. JSI also can begin the financial modeling and engineering required for an accurate network construction budget.

What to Expect in Round 3
Although the Round 3 competition has not yet been announced, RUS did publish ReConnect rules in the Federal Register, which became effective April 27, 2021. The rules allow for the Funding Opportunity Announcement (FOA) to be shorter and relevant to only the subset of data that can change with each funding year. Expect to also see the following for ReConnect Round 3 once the competition is announced:

  • A minimum acceptable level of broadband will be released to establish qualifying areas;
  • Future speed requirements for application(s) will be documented;
  • RUS will identify and establish what areas will be protected in the new application windows;
  • Additional section specifications, including scoring criteria, eligible service area threshold, and eligible award costs;
  • Identified interest rates for direct cost-of-money loans and, as applicable, reduced interest rates for 100% loans; and
  • Total funding available by category of grant, grant/loan combination, and 100% loan for Round 3.

If you’d like more information about ReConnect Round 3, or if you’d like to get started on your company’s application, contact Valerie Wimer in JSI’s Maryland office at 301-459-7590 or Lans Chase in our Georgia office at 770-569-2105.

Webinar: A Guide to the CARES Act

2020-04-09T14:53:19-04:00April 9, 2020|Webinar Recordings|

The Coronavirus Aid, Relief, and Economic Security Act, or the CARES Act, enacted by Congress and signed into law on March 27 contains several provisions and opportunities for rural telecom companies. The federal legislation provides additional money for rural broadband, telehealth programs, and distance learning. Plus companies are eligible for emergency loans designed to help them with the unplanned expenses they’re incurring as they respond to the COVID-19 crisis.

Our free webinar, “A Guide to the CARES Act,” provided a rundown of the stimulus bill’s telecom items, as well as possible future legislation, further response from the FCC, and what some states are doing to help. You’ll learn about the telecom-specific items in the CARES Act, including the $100 million in additional grants for the RUS ReConnect Program, $25 million for the RUS Distance Learning and Telemedicine Program, and $200 million for the FCC’s Connected Care pilot project. We also outlined loans available from the Small Business Administration to help companies affected by the COVID-19 crisis and looked at other key healthcare and small business items included in the CARES Act.

If you would like a copy of the webinar recording, please send your request to Brenda Cordwell. If you have questions about the CARES Act, please contact Douglas Meredith. If you’d like more information on JSI’s COVID-19 Financial Impact Model, please reach out to Steve Meltzer or Bhavini Sokhey at 301-459-7590.

JSI Celebrates Clients’ Outstanding ReConnect Round One Success

2021-04-05T15:06:18-04:00January 30, 2020|News|

Prepared to Assist Companies with Round Two Applications Due March 16

JSI congratulates the rural companies it helped to apply and land more than $116.2 million in grants and loans so far in the first round of the U.S. Department of Agriculture’s (USDA’s) ReConnect Pilot Program. The program distributes funds to build broadband infrastructure in unserved and underserved communities throughout rural America. Of the companies JSI worked with in round one, more than 60% of them were successful. USDA began naming the ReConnect first round winners last fall and continues to publicize new winners, but several JSI clients’ awards have not yet been formally announced.

So far, seven of our clients’ first round awards have been announced:

Star Telephone Membership Corporation will use its $23.7 million grant to build over 535 miles fiber-to-the-premises (FTTP) broadband facilities in North Carolina, which will pass 4,462 possible service locations consisting of farms, businesses, residential and critical community institutions.

Wabash Telephone Cooperative, Inc. in Illinois will use $12.8 million split 50/50 between a grant and a loan to deploy 298 miles of fiber-optic cable in unserved areas of Jefferson and Wayne counties. This investment is anticipated to reach 1,684 households, 31 farms, 29 businesses, nine educational facilities, two critical community facilities and one health care center.

Home Telephone Company will use its $8.1 million grant to deploy 96 miles of fiber-optic cable in unserved areas of Charleston and Berkeley counties in South Carolina. Home will provide matching funds to complete the project, which includes 3,780 households, 19 educational facilities, and eight critical community facilities spread out over 219 square miles.

Wilkes Telephone Membership Corporation Inc. will use a $48 million loan to construct a FTTP network throughout 1,847 square miles in nine Virginia counties. The service area is expected to reach 22,604 households, 19 educational facilities, eight critical community facilities and one health care center.

Green Hills Telephone Corporation in Missouri will use a $2.6 million grant to expand its FTTP network to rural areas in Caldwell and Livingston counties. This investment is expected to reach 20 pre-subscribed farms, 20 pre-subscribed businesses, 546 households, a fire protection district and two educational facilities.

Duo County Telephone Cooperative Corporation Inc. in Kentucky plans to use its $18.7 million grant to deploy a FTTP network in rural Adair, Cumberland and Russell counties. The funded service areas include almost 3,650 households spread over 45 square miles.

Thacker-Grigsby Telephone Company Inc. will use a $2.3 million grant to deploy a FTTP network in rural Breathitt County in east Kentucky. The funded service area includes 637 households spread over 109 square miles.

Looking Ahead to Round Two
The second round of the ReConnect program kicks off on Friday, January 31, with the opening of the application window. USDA will distribute $550 million in additional grants and loans during round two. Applications are due March 16, 2020.

JSI will once again assist companies compete for ReConnect funds. We can help with all aspects of project applications and planning, including mapping of potential funding areas, preparing the required financials, performing a competitive analysis of the potential areas, and shepherding clients through the full application process.

If your company is interested in applying for a ReConnect award or if you have any questions about the program, please contact Valerie Wimer at 301-459-7590 or Lans Chase at 770-569-2105. JSI also held a free webinar in December on ReConnect Round Two. If you missed it, you can request a copy of the recording by emailing Janee Devis.

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