Legacy CAF-BLS companies that may not have adequate locations in the HUBB for a random sampling before broadband performance pre-testing begins in January 2022 must contact USAC by Monday, November 8, 2021. All Legacy CAF-BLS companies, along with A-CAM II, Alaska Plan and CAF Phase II Auction carriers, must begin pre-testing in first quarter 2022 as part of the FCC’s performance measures testing framework. Companies will use a USAC-generated random sample of broadband locations deployed (and reported in the HUBB) that have active subscribers.

However, USAC has identified three scenarios where CAF-BLS companies may not have any locations or enough locations reported in the HUBB for the random sampling:

  1. Fully Deployed Prior to May 25, 2016 – Under this scenario, CAF-BLS companies have not reported any locations into the HUBB because they were fully deployed in their service territory prior to May 25, 2016 and therefore have no HUBB filing obligations.
  2. No Reported Deployments to Date – Since CAF-BLS companies only have one deployment milestone at the end of 2023, there may be some companies that do have a HUBB filing obligation but have not yet submitted any locations in HUBB due to no deployment of 25/3 broadband during the period May 25, 2016 to present.
  3. Limited Deployment to Date – Under this scenario, CAF-BLS carriers have entered some locations in the HUBB due to deployment of 25/3 broadband after May 25, 2016 but must rely on locations that were fully deployed prior to May 25, 2016 to meet their buildout obligations. For example, a company may have a buildout requirement of 3,000, but 2,800 of these were prior to May 25, 2016 and therefore only 200 locations are in the HUBB.

USAC has asked any Legacy CAF-BLS companies that fall under scenarios 1 and 2 to contact them at HCproduct@USAC.org by November 8. USAC is meeting with the FCC to discuss scenario 3 and is planning to send an updated email with language that is directly applicable to this situation. USAC is likely to ask companies under scenario 3 to tell them how many locations and at what speeds were deployed pre-2016 to be added to those that they did upload into HUBB. Regardless, USAC will follow up with CAF-BLS companies under each of the three scenarios on how to obtain random location samples for speed and latency pre-testing in 2022.

If you have any questions about this requirement or any other questions related to broadband performance testing, please contact Lans Chase at 770-569-2105 or Paul Nesenson at 651-452-2660.