By Sonya Goodanetz on 09/07/19 10:35 AM
Protecting your FCC broadband funding and what you need to consider
In an environment where “proof” is the new norm to secure your well-deserved FCC broadband funding, are you ready to complete the federally mandated speed and latency testing of your network to comply with the FCC Performance Measures compliance framework?
If you’re a service provider participating in the Connect America Fund (CAF-II), Alternative Connect America Cost Model (A-CAM), Rural Broadband Experiments, (RBE), Rural Digital Opportunity Fund (RDOF), or Alaska Plan programs, you are probably aware that you must start conducting speed and latency pre-testing of your network every quarter to comply with the new FCC Performance Measures compliance framework depending on your program funding milestones. Operators receiving these funds are required to submit performance measure results of broadband locations with active users to USAC at the end of every quarter to ensure US government investments are being put to proper use in helping to close the digital divide across America. Although official performance testing is set to begin soon for select funding programs, and operators will not face any threat of penalties during the pre-testing phase, there is still a need for service providers to keep the speed and latency test capability high on the “to do” list for 2021. Official test deadlines are 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 who rely 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 and latency
- Not meeting the promised service quality levels and 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 compliance performance and measurement testing? Here are some items to be aware of:
- Which subscribers spanning all speed tiers and devices to put under test
- Subscriber intrusion and privacy – if you choose an approach that requires additional hardware onsite, you may meet some resistance from customers and additional CAPEX
- If you have unmanaged 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, and that support TR-143
- What is the skill set of your technical resources? They will likely require more training and this can add an additional cost burden and time dedicated to run the performance measurements if you aren't using a device management solution
- The FCC order DA-18-710 endorses the Broadband Forum TR-143 as a preferred testing method – check that your devices support this protocol
With all of this in mind, start looking into the different options for how to comply. This could range from a home-grown, system, white box hardware, single-source OEM network management, or standards-based device management software to perform the test measurements. In this blog, we tackle home-grown approaches!
Service providers may have previously considered in-house development, a "one-off" software implementation, or ad-hoc manual reporting for regulatory reporting. If a service provider extends a current process or attempts to build their own system, 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/TR-369 integration expertise and TR-143 familiarity. This poses a challenge, not only from addressing the Broadband Forum's deep technical standards but ensuring a future-proof FCC reporting platform that meets Universal Service Administrative Company (USAC) defined reporting template requirements.
This FCC 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 five resources in terms of manpower. 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, such as white-label hardware, OEM, and device management software, along with key considerations to assist with your planning.
Need help with your FCC testing? Learn more about Incognito’s speed and latency performance testing solution.