Preparing for the FCC Performance Measurement Deadline – Part 1

Protecting your CAF-II and A-CAM funding and what you need to consider

In an environment where “proof” is the new norm to secure your well deserved FCC broadband funding, will you be ready to verify your contracted service quality before Q1 2020?

A May 30th, 2019 announcement from the FCC communicated a delayed test start date for speed & latency performance measurements. The service quality test results constitute a subset of operator USAC filings for those service providers receiving funding under programs such as CAF-II (Connect America Fund), A-CAM (Alternative-Connect America Model), and Alaska plan. While the regulatory order originally called for a July 1, 2019 test start, the window has now shifted to beginning Q1 2020. Industry opposition around alignment of test deadline, funding and deployment dates, in addition to the systems work required to certify customer premise equipment, building new interfaces are all factors contributing to the delay. Despite the decision to postpone the opening of the test window, there is still a need for service providers to keep the speed and latency test capability high on the “to do” list for 2019. 2020 is quickly approaching, so preparation is imperative: run testing and fine-tune the network from test results to verify network service quality before the start date.

Non-compliance yields a financial impact ranging from 5% to 25% per month. Withheld government funding hurts, and is devastating to smaller operators relying on this funding for service expansion. These funding penalties may occur due to:

  • incomplete test results - such as a delayed test start, or incomplete windows
  • inaccurate results - non-conformance to test methodology for speed & latency
  • not meeting the promised service quality levels & minimum connectivity targets

Even more challenging - if you don't meet the government targets, you are subject to even greater regulatory filing requirements.

So, what do you do as a service provider to get prepared for the compliance performance and measurement testing in 2020? Here are some items to be aware of:

  • Random device sampling for speed & latency test - you need to be able to test all CPEs, not just a subset, over time
  • Subscriber intrusion and privacy - if you choose an approach that requires additional hardware onsite, you may meet some resistance from customers and additional CAPEX
  • FCC USAC test reporting framework is not yet finalized
  • If you have un-managed remote devices, now may be the time to consider a remote device management solution with built-in functionality to comply with the FCC requirements. But be aware of the perils of choosing a solution that can only manage specific vendor devices vs. one that gives you the flexibility to manage all devices, regardless of vendor
  • What is the skill set of your technical resources? They will likely require more training and this can add an additional cost burden

With all of this in mind, start looking into the different options for how to comply. This could range from a home-grown system to a white box option and more. Let’s talk about a home-grown approach in this blog.

Home Grown Approach

Service providers may have previously considered in-house development, a “1 off” software implementation or ad-hoc manual reporting for regulatory reporting. The FCC order is the first time network service quality needs to be measured. If a service provider extends a current process, or endeavours to build their own, extensive scripting and use of open-source test tools would be needed with the resources to architect, build, operate and maintain the solution. In-house resources should have TR-069 integration expertise, and TR-143 familiarity. This poses a challenge, not only from addressing the Broadband Forum deep technical standards, but ensuring a future-proof FCC reporting platform. Note also that the Universal Service Administrative Company (USAC) is the agency contracted by the FCC to develop the platform to ingest the reporting data from CSPs, and the final reporting framework has not yet been released. So, there will be some adjustments and alignment along the way to keep in mind.

This regulatory order is not as simple as a “ping” test. The FCC performance measurement technical requirements are robust and could be challenging to implement consistently given the random nature of the testing. Many regional operators including WISPs, for example, have typically less than 5 resources. You need a solution that minimizes the additional drain on these resources who are maxed out today doing operational upgrades, technical support and more.

In Part 2 of this blog series, we will examine other solution approaches and key considerations to assist with your planning.

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