We’ve been conducting large-scale measurement studies for regulators for over 10 years internationally. Different regulators around the world have different requirements for their studies and/or programs, so for smaller ISPs that are looking to become certified by their country’s regulator or meet the standards of a national broadband program, we can help them achieve that – in record time. In the United States, working with Cincinnati Bell was our first time helping an ISP comply with Connect America Fund (CAF) requirements.
The FCC’s Connect America Fund and Rural Digital Opportunity Fund
In the U.S., the Federal Communications Commission (FCC) has programs called the Connect America Fund (CAF) and the Rural Digital Opportunity Fund (RDOF), which provide funding to ISPs to extend broadband services to hard-to-reach areas of the country. ISPs that accept this funding must ensure that the broadband service they provides meets certain speed and latency requirements. ISPs that began receiving CAF funding in 2015 were required to begin testing and submitting results of their performance tests beginning in 2020. ISPs awarded support in subsequent CAF rounds and the 2020 RDOF Auction must begin testing over a staggered period beginning in January 2022.
In 2 months we helped Cincinnati Bell meet the performance testing requirements associated with its CAF support
After evaluating several options, Cincinnati Bell engaged SamKnows in February 2020 to perform the testing in compliance with the FCC requirements. The SamKnows team worked with Cincinnati Bell engineering and regulatory teams to deploy a solution that was fully compliant with the FCC Performance Measures Reconsideration Order (FCC 19-104) and Cincinnati Bell has been successfully submitting quarterly test results since second quarter of 2020.
The SamKnows support team has been great to work with – always responsive to our requests and more than willing to assist in troubleshooting to ensure that our data submissions meet the specific requirements of the USAC system.
Pat Rupich (Director of Regulatory)
How we did this
To help Cincinnati Bell meet CAF requirements, we handled the process with great care and efficiency, from start to finish. For this process, we:
- Implemented Pre-Testing windows with the ISP client 2 weeks prior to the reporting period, ensured sample compliance, metadata validation, report format validation, geographic validation, etc.
- Ensured a running of methodology without interruption for the designated reporting period
- Post testing window CSV generation based on geographic regions.
- Generated reports in FCC/Universal Service Administrative Company (USAC) compliant format.
- Handled the resolving of processing and data errors
- Answered compliance questioning, data queries, etc. from FCC/USAC
Cincinnati Bell’s test schedule
Cincinnati Bell’s Test Schedule consists of running a test in compliance with FCC Performance Measures Order (DA 18-710). We first initiate a primary test attempt, if it fails, 5 re-attempts to run a test are conducted. 5 seconds of cross-traffic detection per attempted test, for a total maximum of 35 seconds cross-traffic detection. If all 6 tests fail the result is marked as a cross-traffic failure. The test will be reattempted at least 5 times in event of unknown failure, if all 6 tests fail the result is marked as an unknown failure. The schedule is comprised of the Contiguous UDP Latency Test, Multi-Threaded Download, and Upload Test. Starting out, Cincinnati Bell began with 150 Whiteboxes, and to maintain a healthy sample in each geographic area Cincinnati Bell topped-up the panel to maintain at least 50 Whiteboxes per CAF area.
A proven methodology
The FCC trusts our methodology as it’s the same testing methodology used for the Measuring Broadband America (MBA) program, which the FCC has used for many years to measure broadband speeds of the major U.S. ISPs.
Do you need help reporting performance for regulatory compliance?
We’ve been conducting large-scale measurement studies for clients for over 10 years. We’ve developed our own proprietary agents, tests, analytical tools and data pipeline to get new studies up and running quickly, and streaming data back almost instantly.