"When it comes to JSI's activities and accomplishments, don't just take our word for it. JSI is always active - working with clients ... debating policy proposals in association and industry forums ... meeting with FCC and PUC staff on regulatory initiatives ... providing testimony in federal and state proceedings ... the list goes on and on. Frequently, the efforts of our staff, win or lose, elicit response from our clients and other industry partners. So, like we say, don't just take our word for it; listen to what some of our clients and friends have to say ...."
-- Manny Staurulakis, president; and Leo Staurulakis, EVP
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JSI worked with several clients that made successful application for RUS broadband stimulus funds in Round 2 of the ARRA process, and company representatives wrote to acknowledge their appreciation:
"Thank you, John (Kuykendall), and congrats to JSI also, as they are our partner in this! We could not have done our application without the expertise of your team ... we are truly grateful for your help. ... I know that we will be turning to all of you during the course of this process for assistance."
"Team: As you have heard by now, (our company) is a recipient of the ARRA stimulus funding. I want to thank you for your valuable contributions to our application to make this a reality for (us)."
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As many clients are aware, a flaw in the DEM weighting factor festered for a number of years. A measure of switch usage, the DEM factor is used to allocate local switching equipment costs between the state and interstate jurisdictions by means of relative values or percentages. Almost four years ago (April 2006), JSI first called the FCC's attention to the flaw, which penalized cost companies that fell below a DEM weighting threshold due to access line loss. The FCC rules were silent about ILEC study areas that saw a decrease in access lines to a level below a given threshold, thus prohibiting an ILEC from moving up to a higher factor. As a result of this imbalance, JSI's cost-company clients falling below a DEM weighting threshold due to a loss in access lines were penalized in the calculation and receipt of local switching support.
In a prolonged series of ex parte meetings and comments, JSI urged the FCC to change the rule and apply DEM weighting changes to both increases and decreases as the number of access lines crossed a threshold. In an order released in March, the FCC finally issued the long-anticipated changes to it rules governing the DEM weighting factor.
A number of clients significantly affected by the DEM imbalance worked with JSI to convince the FCC to address the flaw and change the rules. An executive of one of those clients wrote to call attention to JSI's persistence and resolve staying the course:
"John (Kuykendall), we really appreciate the tremendous help (JSI) gave us on pushing this issue over these past years. It is a significant financial help to us even if we can't go back to 2008-2009. I know you are a real veteran in dealing with the FCC, have more realistic expectations than I do, and probably are a more patient man than I am, but I have to admit I've become a real cynic in terms of (regulators) accomplishing anything significant in any timely fashion. If they can't handle even (simple issues) as with this DEM issue, how in the world will they deal with the National Broadband Plan? I guess the answer is to have good people like yourself pushing them! It's been a pleasure working with you on this issue."
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A client's attorney called attention to JSI's Douglas Meredith's help with a case. The state tax court reversed a ruling that the client company was subject to utility receipts taxes on SLC and FUSC recovery, as well as on distributions received through federal and state "subsidy" programs:
".... thought you might be interested to see the Tax Court's opinion in the [client's] case in which Douglas (Meredith) was our expert witness in January. The judge ruled in our favor on all issues, and it is clear to me that having Douglas' testimony was important in achieving this outcome .... The State is likely to try to appeal this decision, and therefore it is not final at this point. However, we cleared a big hurdle when we were able to get the Tax Court to rule for us. Thanks for your help."
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In our Texas office, several Oklahoma clients took the time to pass on their particular thanks to Craig Cook and the staff for their efforts helping them stay abreast of various regulatory and industry developments:
"I just want to say thank you. There is so much going on in the industry; I couldn't survive without your help. Just wanted to say, ‘Thanks a million," - I appreciate you and all that you do."
"Craig, thanks for staying current with all these events happening in Oklahoma and especially for helping me understand and make it through these issues with your advice and insight. Not sure how things will continue to proceed, but with the elections coming up before too long it could change everything... I am not sure if that will be bad or good but will hope whatever the outcome we will get the best results."
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And a new client detailed his company's experience since shifting its cost study work to JSI:
"(We) recently acquired the services of JSI all our cost study-related work. In addition to the annual study, this also includes forecasts, quarterly and annual high-cost loop filings, NECA reporting, and Central Office CPRs. I would also note that several months ago, we had transferred our regulatory work as well as special projects including CALEA, long-distance implementation and billing issues, marketing and bundling, and interconnection negotiations to JSI. This transition ... went very smoothly, and we have found JSI staff to be very knowledgeable of the industry, as well as being professional and responsive to our needs. Thus far, we have been very pleased. The work performed by JSI has been so impressive it is hard to put into words. I recommend JSI and would be happy to discuss our experiences in more detail."
