On October 16, WTA met with staff from the office of Commissioner O’Rielly. WTA reiterated its support for performance testing that fairly and accurately measures speed and latency for a sample of the locations for which they have received CAF support and expressed appreciation for the Order’s revised formal testing start dates for RLECs, particularly for the 12-month pre-testing periods that precede formal testing.
WTA noted that the draft Order rejects most of the small carrier alternatives that had been advanced, including those regarding testing end points, daily and quarterly testing, and the number of testing locations.
WTA proposed a solution to many of these performance testing issues – specifically that, in addition to allowing CAF recipients to become familiar with their testing equipment and the testing process, the 12 month pre-testing periods be used to collect data that can address the uncertainties and differences that remain unresolved between the Commission’s staff and the industry.
WTA requested that the Order on Reconsideration make a specific and explicit commitment to encourage and allow the data collected during the 12-month pre-testing periods to be used by RLECs to request and obtain a fresh look not only at performance measures but also at testing end points and other performance testing issues for which Commission is rejecting industry proposals and concerns in this draft and that the Order expressly indicate that requests for a fresh look will not be dismissed or denied on the grounds that they constitute untimely petitions for reconsideration or applications for review of the present order. WTA suggested language to achieve this goal.