All A-CAM I, Rural Broadband Experiment (RBE), and Alaska Plan recipients are required to submit their first quarter of broadband speed and latency test results in USAC’s Performance Measures Module (PMM) by the April 7, 2021, deadline for the first quarter’s results. Since 2021 is the “pre-testing” year for this group of companies, it is important to work though the steps involved with the PMM and resolve issues with your equipment and processes prior to 2022 when missing the target measurements will impact funding. During the pre-testing year, companies will not be penalized for missing the speed and latency benchmarks; however, companies can still be penalized for filing data late. It is best to submit whatever testing data you can produce and not be concerned about getting the results perfect in this first pre-testing round, as USAC will work with companies by identifying errors and failed tests.

JSI has heard of issues arising regarding data input into the PMM, running the randomizer, finding test servicers, and actual test results. With only a few weeks left in the quarter, JSI encourages A-CAM I companies experiencing difficulties to have some test results to file. That may mean testing only a portion of the customers selected by the randomizer (i.e., test customers that don’t need any on premise equipment first, then move to customers that do required CPE installation). Issues with equipment and finalizing testing locations can be addressed throughout the year.

Issues include: –

  • In December, the FCC released an Order that permits companies to pre-test only 70% of their USAC-generated random samples during 2021 (See our December 23, 2020, e-Lert). This could alleviate issues with finding suitable replacement locations in time if the testing sample contained locations that need to be replaced.
  • A-CAM I, RBE, and Alaska Plan companies having trouble with completing the testing on time due to COVID hardships can file a waiver. The FCC “may take into account considerations of hardship, equity, or more effective implementation of overall policy on an individual basis.” Certain hardship waivers could include company employee deaths, equipment delays due to COVID, customers not permitting technicians in their homes, or other unplanned situations that prevent the testing from being completed and submitted. Even with a waiver, companies should work towards resolving their individual hardships to comply with the rules and be ready for the 2022 testing period.

JSI and N-Com can assist companies with the final leg of the first quarter of broadband testing with reviewing data prior to filing, troubleshooting equipment challenges, drafting a hardship waiver, and providing guidance on the PMM and randomizer process. We encourage A-CAM I, RBE, and Alaska Plan clients to engage us on the filing process and with any assistance you need in resolving issues with USAC or completing the follow-up analysis after the quarterly filings.

If you have questions about the broadband pre-testing or need assistance with this upcoming filing, please reach out to Valerie Wimer in the Maryland office at 301-459-7590 or Paul Nesenson in our Minnesota office at 651-691-4045.