Mike, My concern regarding the Enhanced A-CAM program is the exact same problem I have with the "new" FCC National Broadband Map and the FCC mandated ISP Broadband Label and the BEAD funding provision on the requirement that ISPs receiving funding ensure device on the customers premises testing for Speed -Latency (BEAD NOFO program page 64 i. Speed and Latency)
Can you guess what it is? Wait for it, every data point reported/posted or measurement taken is done by the ISPs. This entire theater of the absurd continues the FCC/ISP (Carriers) preference (of course) for a NON-TRANSPARENT, NON INDEPENDENTLY VALIDATED DATA BASED BROADBAND MARKETPLACE ...Just like they have insisted on from the beginning of the E-RATE program which, wait for it, in NOT TRANSPARENT and everyone associated with the E-RATE "Reform" NOPR back in the day knew the program even then had about 40% waste fraud and abuse built in but as the FCC staffer stated time and time again they didn't have the manpower to go after this egregious situation so the whole "reform" exercise was a way to justify and increase on the tax/fees that supported the program with the extra funds coming in being discounted by at least 40%!
Consumers what a TRANSPARENT BROADBAND MARKETPLACE and they want to be able to TRUST THE ISPs DATA (a truly revolutionary concept)
Here is how we have defined the current broadband ecosystem at PAgCASA and how we have designed the State level solution.
We are not under any elusions at PAgCASA and realize only a few states will see the positive effects of empowering their constituents with a transparent broadband marketplace and data they can trust.
THE PROBLEM
• Broadband Data is unreliable
o ISP reported data on the New FCC National Broadband Map Inflates network speed and territory served.
o Consumer generated speed test data faces technical challenges and is largely unreliable as are crowdsourcing data analytics and alike.
• The Broadband Marketplace is not transparent, with all the power residing with the ISPs, not with consumers.
o The FCC has exercised little enforcement when it comes to consumer’s complaints and that will continue.
THE SOLUTION
• Leverage NTIA’s NOFO BEAD program- i. Speed and Latency (page 64, language below) to begin to build out a statewide, independent third-party run broadband monitoring/metering program where:
o ISPs pay an independent third party (PAgCASA) to lease edge cyber secure industry standard network monitoring devices (the same ones used by Verizon/AT&T/Comcast) as mandated by the BEAD funding requirements, with PAgCASA , not the ISP, monitoring the edge secure data.
• Have your State, not the ISPs, oversee an independent, third-party data validation process to ensure the information on the new FCC mandated ISP Broadband Labels, designed to give much needed information about network performance and pricing to consumers, is accurate. Have the ISPs share the cost associated with this information validation program designed to protect consumers.
THE COST
If your State follows the formula outlined above the ISPs in your State will be responsible for underwriting the expenses associated with your State having the most up to date and accurate broadband State map and the best consumer empowering Broadband Marketplace.
Your State Needs a Broadband Sheriff to Enforce the Authority NTIA and the FCC have Already Put in Your hands, and to make the ISPs pick up the Tab!
The entire broadband network ecosystem is defined by two distinct data sets both of which are unreliable.
ISPs, with the implicit consent of their regulatory agency, the FCC, have for several decades been able to inflate their network service speeds (Advertised/Marketing Network Speed), quality of service and service territory (FCC’s Ten Day Rule). The Old FCC Broadband Map was roundly criticized for its inaccurate data as is the New FCC Broadband Map.
Technical problems associated with customer generated speed testing data is well known, and its flaws well documented.
Your State has been given the authority it needs to police your ISPs (see NTIA NOFO paragraph below) and FCC’s New Broadband Labeling Requirement (see below) leaves it up to the States to validate/ensure the accuracy of the new ISPs labeling information!
PAgCASA’s Statewide Broadband Sheriff initiative has the industry standard monitoring/metering devices and edge cybersecurity for data protection needed to launch a statewide “trust but verify” initiative with the ISPs picking up the cost of leasing the devices while PAgCASA monitors the device, stores the data in a SOC and works with the State or the State’s Broadband Mapping partner to display the validated data.
NTIA NOTICE OF FUNDING OPPORTUNITY BROADBAND EQUITY, ACCESS, AND DEPLOYMENT PROGRAM EXECUTIVE SUMMARY
i. Speed and Latency
To ensure that Funded Networks meet current and future use cases and to promote consistency across federal agencies, NTIA adopts the compliance standards and testing protocols for speed and latency established and used by the Commission in multiple contexts, including the Connect America Fund and the Rural Digital Opportunity Fund.78 In order to demonstrate continued compliance with these standards, subgrantees must perform speed and latency tests from the customer premises of an active subscriber to a remote test server at an end-point consistent with the requirements for a Commission-designated IXP.79
Mike, My concern regarding the Enhanced A-CAM program is the exact same problem I have with the "new" FCC National Broadband Map and the FCC mandated ISP Broadband Label and the BEAD funding provision on the requirement that ISPs receiving funding ensure device on the customers premises testing for Speed -Latency (BEAD NOFO program page 64 i. Speed and Latency)
Can you guess what it is? Wait for it, every data point reported/posted or measurement taken is done by the ISPs. This entire theater of the absurd continues the FCC/ISP (Carriers) preference (of course) for a NON-TRANSPARENT, NON INDEPENDENTLY VALIDATED DATA BASED BROADBAND MARKETPLACE ...Just like they have insisted on from the beginning of the E-RATE program which, wait for it, in NOT TRANSPARENT and everyone associated with the E-RATE "Reform" NOPR back in the day knew the program even then had about 40% waste fraud and abuse built in but as the FCC staffer stated time and time again they didn't have the manpower to go after this egregious situation so the whole "reform" exercise was a way to justify and increase on the tax/fees that supported the program with the extra funds coming in being discounted by at least 40%!
Consumers what a TRANSPARENT BROADBAND MARKETPLACE and they want to be able to TRUST THE ISPs DATA (a truly revolutionary concept)
Here is how we have defined the current broadband ecosystem at PAgCASA and how we have designed the State level solution.
We are not under any elusions at PAgCASA and realize only a few states will see the positive effects of empowering their constituents with a transparent broadband marketplace and data they can trust.
THE PROBLEM
• Broadband Data is unreliable
o ISP reported data on the New FCC National Broadband Map Inflates network speed and territory served.
o Consumer generated speed test data faces technical challenges and is largely unreliable as are crowdsourcing data analytics and alike.
• The Broadband Marketplace is not transparent, with all the power residing with the ISPs, not with consumers.
o The FCC has exercised little enforcement when it comes to consumer’s complaints and that will continue.
THE SOLUTION
• Leverage NTIA’s NOFO BEAD program- i. Speed and Latency (page 64, language below) to begin to build out a statewide, independent third-party run broadband monitoring/metering program where:
o ISPs pay an independent third party (PAgCASA) to lease edge cyber secure industry standard network monitoring devices (the same ones used by Verizon/AT&T/Comcast) as mandated by the BEAD funding requirements, with PAgCASA , not the ISP, monitoring the edge secure data.
• Have your State, not the ISPs, oversee an independent, third-party data validation process to ensure the information on the new FCC mandated ISP Broadband Labels, designed to give much needed information about network performance and pricing to consumers, is accurate. Have the ISPs share the cost associated with this information validation program designed to protect consumers.
THE COST
If your State follows the formula outlined above the ISPs in your State will be responsible for underwriting the expenses associated with your State having the most up to date and accurate broadband State map and the best consumer empowering Broadband Marketplace.
Your State Needs a Broadband Sheriff to Enforce the Authority NTIA and the FCC have Already Put in Your hands, and to make the ISPs pick up the Tab!
The entire broadband network ecosystem is defined by two distinct data sets both of which are unreliable.
ISPs, with the implicit consent of their regulatory agency, the FCC, have for several decades been able to inflate their network service speeds (Advertised/Marketing Network Speed), quality of service and service territory (FCC’s Ten Day Rule). The Old FCC Broadband Map was roundly criticized for its inaccurate data as is the New FCC Broadband Map.
Technical problems associated with customer generated speed testing data is well known, and its flaws well documented.
Your State has been given the authority it needs to police your ISPs (see NTIA NOFO paragraph below) and FCC’s New Broadband Labeling Requirement (see below) leaves it up to the States to validate/ensure the accuracy of the new ISPs labeling information!
PAgCASA’s Statewide Broadband Sheriff initiative has the industry standard monitoring/metering devices and edge cybersecurity for data protection needed to launch a statewide “trust but verify” initiative with the ISPs picking up the cost of leasing the devices while PAgCASA monitors the device, stores the data in a SOC and works with the State or the State’s Broadband Mapping partner to display the validated data.
NTIA NOTICE OF FUNDING OPPORTUNITY BROADBAND EQUITY, ACCESS, AND DEPLOYMENT PROGRAM EXECUTIVE SUMMARY
i. Speed and Latency
To ensure that Funded Networks meet current and future use cases and to promote consistency across federal agencies, NTIA adopts the compliance standards and testing protocols for speed and latency established and used by the Commission in multiple contexts, including the Connect America Fund and the Rural Digital Opportunity Fund.78 In order to demonstrate continued compliance with these standards, subgrantees must perform speed and latency tests from the customer premises of an active subscriber to a remote test server at an end-point consistent with the requirements for a Commission-designated IXP.79
https://www.fcc.gov/broadbandlabels