High Cost CAF Compliance Outreach

Script to open the conversation for the small discussion groups:

“USAC is gathering stakeholder input and feedback as it develops a process for verifying broadband deployment by the carriers receiving Universal Service Fund (USF) High Cost support. Carriers participating in Connect America Fund (CAF) programs must report broadband deployment data via USAC’s new High Cost Universal Broadband (HUBB) portal showing where they are building out service by precise location (latitude/longitude coordinates). The HUBB performs a number of automated checks to validate this data (e.g., such as determining whether a location’s latitude/longitude coordinates fall within a carrier’s eligible area). In order to verify the accuracy of the information submitted, USAC is also designing an in-depth review of compliance for a subset of participants. This in-depth review could include, but is not limited to, confirming service availability through customer subscription records or online service qualification tools showing that service is available at a particular sample of locations within the state. USAC is seeking stakeholder input on ways it can implement an in-depth verification process that is not overly burdensome for participants but will provide sufficient documentation to ensure proper use of CAF support.”

USAC will use the following questions to guide the conversation to gather information about what questions and documents could be used to verify compliance with broadband deployment obligations:

• How carriers design and document their network construction, what technologies carriers use to deliver qualifying broadband speeds, and to measure the quality (QoS) of the deployed broadband service and whether an engineer could use that information to certify test results as well as evaluate service availability?

• What do carriers do today to safeguard the privacy of subscriber information (PI and CPNI)?

• How do carriers track deployment internally and measure broadband performance?

• How do carriers collect and report served locations pursuant to 47 C.F.R. § 54.316 and how is this process documented?

• What others types of documentation and evidence demonstrate broadband deployment, such as subscriber bills, network maps or service availability tools?

• Is there a role for outside engineers, consultants or construction firms to provide independent confirmation of carrier build-out?