eLert | JSI
March 12, 2015   View as web page          

The FCC released its Net Neutrality Order this morning on its website.

JSI is reviewing the Order’s details and we’ll be sending clients an e-Lert early next week regarding the rules’ effects on their operations. Also, we’re planning a webinar on the Net Neutrality rules – look for that announcement soon.

Rural Call Completion Rules Are Finally Effective; Data Recording Starts April 1

About 16 months after the rules were first adopted, last week the Office of Management and Budget (OMB) approved the FCC’s Rural Call Completion Recordkeeping and Reporting Requirements. Rural call completion problems have troubled the industry, and especially rural consumers who cannot be reached by landline, for years without significant improvement in the matter. The FCC has issued several enforcement actions, and now the new recordkeeping and reporting requirements are moving forward—it remains to be seen if any positive impact on the problem will be achieved.

Entities that must comply with the recordkeeping and reporting requirements (FCC Form 480) are called “covered providers.” Covered providers are long-distance voice service providers that make the initial call path decision and have more than 100,000 domestic retail subscriber lines (including all business, residential, and mobile subscriber lines). Covered providers include local exchange carriers (LECs), interexchange carriers (IXCs), commercial mobile radio services (CMRS), and voice over IP (VoIP) providers; however because of the 100,000 line reporting threshold, very few RLECs will qualify as a covered provider. The first Form 480 will be due August 1, 2015, and cover data collected for the months of April, May, and June. Additionally, long-distance voice providers that do not make the initial call path decision, but have more than 100,000 domestic retail subscribers, will need to file a letter by April 1 explaining why they are not subject to the recordkeeping and reporting requirements.

Already, the FCC has concluded some enforcement actions against covered providers, and we expect to see additional enforcement actions by the FCC this year. As part of its Consent Decree, Verizon is required to hold a workshop on rural call completion problems in April. For more information about the status of rural call completion problems, the recordkeeping and reporting requirements, and ongoing advocacy efforts at the FCC and on the Hill, contact Cassandra Heyne and John Kuykendall in the Maryland office at 301-459-7590. JSI can assist with ex parte visits and communications to lawmakers on this serious call completion problem in rural America.

April 1 Deadline for Service Accessibility Compliance Certification Filing

JSI clients are reminded of the upcoming April 1 deadline to submit their certifications to the FCC concerning accessibility of services to the disabled.  The rules apply to all telecommunications providers, as well as to providers of advanced communications services and mobile phones with web browsers. 

The filing must be completed via the FCC’s Recordkeeping and Compliance Certification and Contact Information Registry at  Providers are to certify their compliance for calendar year 2014.  Specifically, providers are to certify operating procedures have been established 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.
Certifications and contact information must be submitted for your company and for each affiliate that provides telecom services.  If previously submitted contact information remains current, the 2015 submission need only include the new compliance certification.  We remind clients that any updates to contact information must be made in the online registry within 30 days of the change. 

Clients who need assistance with the filing may contact Kim Waldvogel ( in the Maryland office at 301-459-7590.

May 26 Deadline For All ILECs to Recertify Study Area Boundary Shapefiles

March 16 Deadline for Any Modified Shapefiles

In 2013, the FCC required all incumbent local exchange carriers (LECs) to submit study area boundaries in shapefile format. These boundaries must be recertified by an officer every two years. The next recertification deadline is May 26, 2015. FCC staff has communicated that they are still preparing the online certification process, which will be available here: JSI will alert clients once the site is available and can assist with the certification process.

Additionally, any ILEC that needs to resubmit modified study area boundary shapefiles must do so by March 16, 2015. ILECs could have boundary modifications as a result of ongoing efforts to reconcile gaps and overlaps with neighboring ILECs, or if an exchange was purchased from another entity. If you believe you need to resubmit a study area boundary shapefile and need assistance, please contact JSI immediately.

For questions about the study area boundary shapefile resubmission and recertification process, contact Cassandra Heyne in the Maryland office at 301-459-7590.


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John Kuykendall

Cassandra Heyne

Kim Waldvogel

Mark Your Calendar

March 16
Modified shapefiles due to the FCC

April 1
Accessibility Recordkeeping Compliance Certifications due to the FCC

April 1
Early Bird rates end for JSI's 2015 Management Seminars

May 26
ILEC study area boundary shapefile recertification deadline

Register Now for Our 2015 Management Seminars

One of the sessions at our upcoming Management Seminars will be on the effects of today's Net Neutrality rules on your operations, as well as others on broadband policy, federal Universal Service reform efforts, IP transition news, changes to E-rate, and more. Register now for one of these important seminars:

May 7-8 in Atlanta
May 18-19 in San Antonio
June 1-2 in Minneapolis

And if you sign up before April 1, you can save on each registration - $745 for the first registrant and $705 for additional registrants. After the Early Bird rates expire, prices will rise to $795 for the first registrant and $750 for each additional registrant from the same company.

Information about CPE credits, hotels and more are available on our website. If you have other questions, you can contact Leah Yoakum, JSI's seminar administrator, 301-459-7590.