WTA Files Application for Review of FCC’s Performance Testing Standards
On Sept. 19, WTA filed an Application for Review with the FCC of the Commission’s Performance Testing Standards. In the Application, WTA requested that the Commissioners review the Bureau-level decisions regarding the amount of performance testing required, the scope of the testing, and the implementation date.
Specifically, WTA recommends that the frequency of testing be reduced to one week per year and the number of locations tested be reduced to between 10 and 15. In addition, the scope of the testing should be limited to the portions of the networks administered by RLECs. WTA also requests that the implementation of the testing be delayed for two years for RLECs (as opposed to larger carriers), which should permit RLEC-compatible equipment to become more available and affordable, and allow qualified third party vendors to determine whether they can and will offer testing services for RLECs.
These changes and others are needed to address the difficulties of obtaining rural testing participants, the high costs of the Order’s testing framework, and the inability of RLECs to control, avoid or repair delays and disruptions caused by poor quality or congested middle mile services and/or customer equipment. In addition, the Commission should not reduce or withhold critical high-cost support from RLECs due to middle mile and customer equipment issues that they cannot control, upgrade or repair.
