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.

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.

Free Webinar: Kicking Off Round Two of the ReConnect Funding Program

2019-12-18T17:01:18-05:00December 18, 2019|Webinar Recordings|

U.S. Department of Agriculture’s (USDA) Rural Utilities Service (RUS) has released the program guidelines for round 2 of its Rural eConnectivity Pilot Program (ReConnect). ReConnect provides $550 million in grants and loans to help pay for building broadband in unserved rural areas that lack 10/1 Mbps. The program’s application portal will open on January 31, 2020, and applications can be submitted through 6 p.m. EST on March 16, 2020.

To help clients prepare for the 2020 program, JSI hosted a free webinar to share important information and updates about the ReConnect Program, including:

  • Changes in requirements and program guidelines
  • Program requirements for grants, grant/loan combinations, and loan funding
  • How to determine eligible areas
  • Who should apply?
  • RUS’s scoring criteria
  • Deadlines
  • Strategies for success

Because of the program’s complexity, we also reviewed several scenarios as examples for each of the three funding options. This webinar should help you determine an eligible area and gather information for a possible application.

To request a recording of the JSI webinar, please contact Janee Devis at 301-459-7590. For more information about the ReConnect program please contact Cassandra Heyne in our Maryland office at 301-459-7590.

RUS to Make Available $600 Million in Grant and Loans

2018-08-06T16:30:38-04:00August 6, 2018|e-Lerts|

Interested Clients Should File Comments 

Earlier this year, a rural broadband pilot program was envisioned and then funded in the Consolidated Appropriations Act of 2018. The U.S. Department of Agriculture’s (USDA) Rural Utilities Service (RUS) will distribute $600 million via a new program called the “e-Connectivity” pilot program that targets support in the form of grants and loans.  Among the conditions attached to the program is that 90% of the households served by any project funded by the program cannot currently have 10/1 Mbps broadband access.  Additionally, any entity receiving funds is prohibited from overbuilding an existing RUS borrower.

RUS has begun the process of drafting rules and procedures for the funding by requesting comments in a Notice of Inquiry (NOI). Comments are due Monday, Sept. 10, 2018, by 5:00 p.m. Eastern. Although RUS is in the early stages of developing the program, we encourage clients that have areas lacking 10/1 to participate in all comment phases. As explained below, RUS has yet to determine whether A-CAM and Legacy carriers can obtain funds for areas in which they are required to meet buildout obligations. Also, RUS is considering including its broadband loan program so that projects could have a mixture of areas lacking 10/1 and 25/3. So participation in advocacy efforts at this stage is key. If interested, please let us know if you would like our assistance in drafting comments.

The purpose of the comments on the NOI is for RUS to set some basic parameters on how to determine where to distribute the funding because the program will be focused on areas that lack 10/1. A request for comments on other items regarding the funding is expected in the Fall in a Public Notice. In this NOI, USDA seeks comment on the following specific issues:

  1. Ways of evaluating a rural household’s “sufficient access” to broadband at speeds of 10/1 Mbps, and how service affordability is factored in
  2. Best options to verify speeds of broadband service provided to rural households
  3. Best leading indicators of the potential project benefits for rural industries such as agriculture, manufacturing, e-commerce, transportation, health care and education, using readily available public data
  4. Methods to evaluate the viability of applications that include local utility partnership arrangements

RUS is considering adding some money from its broadband loan program to the e-Connectivity pilot program, which could increase the total budget to $1 billion for a combination of loans and grants. If this happens, it is possible that areas that lack 25/3 Mbps will be eligible for funding. Additionally, RUS interprets the law to allow A-CAM and CAF-BLS recipients to receive funds in areas where they have defined buildout obligations, which could provide much-needed supplemental funding in areas where either A-CAM or CAF-BLS just doesn’t cover the real costs of deploying broadband in remote areas.

JSI will keep you updated on developments in the e-Connectivity pilot program, and can assist with drafting comments and evaluating opportunities once more information is released. For questions about the e-Connectivity pilot program, contact John Kuykendall or Cassandra Heyne in the Maryland office at 301-459-7590.

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