Access to high-speed Internet in the U.S. has improved significantly over the years, but there are still some unserved and underserved rural communities where slow internet service is impacting the people who live, work and go to school there.  The Federal Communications Commissions’ Connect America Fund (CAF) was designed help close the digital divide between urban areas and rural communities by providing funds to Internet Service Providers to expand broadband services in areas that  otherwise would be too expensive to serve. 

For those operators who received CAF II funds (Phase II of the program), the mandatory speed and latency performance measures were originally set to begin in third and fourth quarters of 2019, with a requirement to report the results by July 1, 2020. After several petitions for reconsideration were raised, the FCC decided to delay the requirement to begin testing until the first quarter of 2020.

The testing is extensive, and along with the forms and certifications that must be completed, the required filing can be a significant undertaking. The time needed to develop procedures to test systems in a consistent manner and compile the data was partly why the FCC delayed the beginning of testing.

Below is an overview of some of the testing requirements, annual filing requirements, and your options for getting it all done on time.

Testing Requirements

Overview

• Live Testing must begin by January 1, 2020
• Data must be sampled and reported to the FCC for 1 week out of each quarter
• Extensive speed and latency tests must be conducted at a specified number of
  subscriber locations
• Download and upload speed tests must be performed hourly, and latency
  tested every minute
• You are required to test a specific number of homes on each speed tier in each state

Additional details for testing compliance requirements:

• Up to 50 locations per CAF-required service tier offering per state must be tested. If there are less than 50 subscribers at CAF-supported locations in a given service tier, the number of testing locations is reduced to five.
• Speed and latency must be tested from the customer premises of an active subscriber to a remote test server located at or reached by passing through an FCC-designated Internet Exchange Point (IXP). 
• An 80/80 standard for demonstration of compliance with speed performance metrics is required (i.e., 80 percent of download and upload measurements must be at or above 80 percent of the CAF-required speed tier).
• A provider’s certified test results must show for each state that 95 percent or more of all tests of network round-trip latency are at or below 100 ms when measured between the customer premises and a remote server located at or reached by passing through an FCC-designated IXP.

CAF II recipients can choose from 3 options for performance testing:

The Commission is allowing carriers some flexibility on the testing methods used. Operators may use:

1. The existing Measuring Broadband America testing program (typically more costly)
2. Existing Network Management Tools and Systems such as the TR-143 Standard (typically more time consuming)
3. Provider-developed testing system (a good choice for many operators to ensure the job gets done accurately and on time)   
      

Annual Filing Requirements

Carriers receiving CAF Phase II support must also complete the following filing and certification requirements for each subsequent year.

• Submit the geocoded locations where you have newly deployed facilities capable of delivering broadband that meets or exceeds the defined speed tiers in the previous year. Submit locations in the HUBB.
• Certify your data by filing FCC Form 481 (Carrier Data Annual Collection Form). File Online
• Certify you have used High Cost funding correctly per program rules. Most carriers are certified by their states. But, if your company is not subject to state jurisdiction, you must file yourself. 
• You must file broadband deployment data with USAC's HUBB (High Cost Universal Broadband) portal showing where you are building out high-speed Internet service. This information includes latitude and longitude coordinates for every location where service is available. The HUBB portal is accessible through USAC's E-File system. Once you are logged in, click on "HUBB" on the left-hand navigation panel.

With the amount of time and effort needed to institute testing and filing procedures, operators may find themselves in need of assistance from a reputable and reliable testing system provider. Don’t risk penalties for non-compliance. Please contact us and let’s talk about your options.