Preparing for the FCC Performance Measurement Deadline – Part 2

Options and technology approaches to consider

The FCC performance measurement deadline in 2020 is fast approaching, and as we explained in the first part of our blog series, there are a number of solution options out there to consider to achieve compliance with the FCC requirements. In Part 1 we looked at home-grown solutions. In Part 2 we will look at the white box approach, device-specific management, and leveraging the capabilities of remote device management with a TR-069 Auto-Configuration Server.

White Box

This approach features a pass-through device or white box placed inside each subscriber premise, and a central test server capturing test data. The subscriber randomness test requirement is tricky. You won’t know which CPEs will be under test from one quarter to the next, so all subscriber CPEs need to be ready for testing, not just a subset of them or a specific vendor device type. This means you may need hardware for all subscribers per state. This is costly from the perspective of CAPEX investment in additional hardware, increased operational costs due to truck rolls for white box installation, and of course, the time pressures of getting this in place and tested ahead of the deadline. You may also face subscribers’ concerns about data privacy (“what the heck is this box for?”), and concern about intruding into their home for regulatory testing.

Device Vendor-led or Device Specific

This next solution moves into the broader network or device management approach where specific device vendors offer a complementary solution to comply with FCC requirements for speed and latency against their devices. If you have a single vendor, and 1-2 device models, this may work for you. However, longer term, this could present vendor lock-in challenges and prohibit you from introducing new devices and vendors. With the consolidation in the US telecom and cable MSO space, and the decreasing cost of CPE hardware, this would result in multi-vendor and multi-network technology test scenarios that would need to be supported. Are all the devices TR-143 capable? What types of firmware upgrades or test clients are required on the CPE devices? Worst case, if the CPEs can’t be patched, you may need to swap out equipment in the subscriber’s home. Another potential hit to hardware cost, customer experience, and time you need to be ready. 

TR-069 Auto Configuration Server 

Another approach to consider is remote device management which leverages a standards-based TR-069 Auto-Configuration Server (ACS) that needs to address the FCC performance measurement requirements out of the box, while also ensuring preparedness for future speed “proof” of on-going regulatory audits. This lessens your operational burden and provides in-home CPE network control remotely to manage and ping into devices. Beware the FCC and USAC may communicate the CSV report format close to the test start date, so seek flexibility to adapt your test data to the regulatory model quickly, in addition to data loading ease into USAC HUBB portal.

An investment in remote device management with an ACS is a major consideration beyond FCC compliance. However, if you are feeling the operational pain today of un-managed devices with extensive truck rolls and long MTTR, then now may be the time to consider implementing device management with the added benefit of a regulatory compliance. Not all ACSs are created equal! You need to ensure that your choice of ACS vendor brings added functionality such as support for digital self-care channels for CSRs and customers, and out of the box reporting and measurement frameworks. 

Technical teams are taxed already, particularly for American Tier 4-6 operators. Burdening operations with regulatory needs of weekly tests, spanning from 6 PM to 12 AM local time across numerous subscribers and speed tiers, is a distraction from working with your customers. If you choose to pursue an ACS-led implementation, ask vendors about the services they can offer in terms of training, implementation, and even an on-going managed services model that can get you up and running quickly without any additional CAPEX investment. 

The Wrap Up

You’re probably thinking, "will it really be up to the provider to determine the subscriber randomness algorithm?" Industry buzz says ‘unlikely’. Once the FCC determines the (late-breaking) rule, customization isn’t going to fly. Make use of software product configuration to target the subscriber devices for the test interval rapidly.

These are all factors to ponder, but don’t mull it over for too long. 2020 will be here before you know it!

Have questions about how you can prepare for FCC compliance testing? Contact us!

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