FCC Record, Volume 26, No. 22, Pages 17663 to 18414, Supplement (November 18, 2011) Page: 17,706
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addition, as part of the federal-state partnership for universal service, we expect and encourage states to
assist us in monitoring and compliance and therefore require funding recipients to send a copy of their
annual broadband performance report to the relevant state or Tribal government.'79
110. Commenters generally supported testing and reporting of broadband performance.'80
While some preferred only certifications without periodic testing,1'8 we find that requiring ETCs to
submit verifiable test results to USAC and the relevant state commissions will strengthen the ability of
this Commission and the states to ensure that ETCs that receive universal service funding are providing at
least the minimum broadband speeds, and thereby using support for its intended purpose as required by
section 254(e).
111. We adopt the proposal in the USF-ICC Transformation NPRMthat actual speed and
latency be measured on each ETC's access network from the end-user interface to the nearest Internet
access point. In Figures 3 and 4 below, we illustrate basic network structure for terrestrial broadband
networks (wired and wireless, respectively). In these diagrams, the end-user interface end-point would be
(5) the modem, the customer premise equipment typically managed by a broadband provider as the last
connection point to the managed network, while the nearest Internet access point end-point would be (2)
the Internet gateway, the closest peering point between the broadband provider and the public Internet for
a given consumer connection. The results of Commission testing of wired networks suggest that
"broadband performance that falls short of expectations is caused primarily by the segment of an ISP's
network from [5] the consumer gateway to [2] the ISP's core network."'82
Figure 3
'79 See infra para. 582.
'o ADTRAN USF/ICC Transformation NPRM Comments at 32; GVNW USF/ICC Transformation NPRM Reply at
26 (must be a process for verifying performance); ICORE USF/ICC Transformation NPRMComments at 12-13
(quality of service obligations and extensive reporting requirements are safeguards that prevent waste and
inefficiency).
181 U.S. Cellular USF/ICC Transformation NPRM Comments at 46-47.
182 Measuring Broadband America Report at 11; see ADTRAN USF/ICC Transformation NPRM Comments at 33-
35 (supporting use of Points 2 and 5 as the end-points for measuring broadband performance).
35 (supporting use of Points 2 and 5 as the end-points for measuring broadband performance).17706
Federal Communications Commission
FCC 11-161
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United States. Federal Communications Commission. FCC Record, Volume 26, No. 22, Pages 17663 to 18414, Supplement (November 18, 2011), book, 2011; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc154713/m1/54/: accessed March 28, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.