It recently changed from being a handful of IXPs to testing to a server that’s in the same building as one of 40+ ASNs:

https://docs.fcc.gov/public/attachments/DOC-360069A1.pdf (page 35ff)

The concern is that many RLEC buy transit from “Tier 2” providers that may are not on that list of ASNs, so they are effectively unable to have SLAs to those test servers and guarantee performance for the required latency and speed tests.  Those receiving the monies aren’t concerned about their local loop or internal network – it’s the transit component that gives them the most heartburn.  The performance testing rules were developed *after* the money was handed out – not fair to be held responsible for network that’s out of their direct and indirect control.

Frank

From: NANOG <nanog-bounces@nanog.org> On Behalf Of Bill Woodcock
Sent: Thursday, October 31, 2019 10:56 PM
To: Sean Donelan <sean@donelan.com>; North American Network Operators' Group <nanog@nanog.org>
Subject: Re: FCC Takes Steps to Enforce Quality Standards for Rural Broadband

On Oct 31, 2019, at 6:42 PM, Sean Donelan <sean@donelan.com> wrote:
There is just so much I want to make sarcastic comments about, but I worry about offending future potential employers (all of them).
https://www.fcc.gov/document/fcc-takes-steps-enforce-quality-standards-rural-broadband-0

"The Bureaus required ETCs to perform speed and latency tests from the customer premises of an active subscriber to a remote test server located at or reached by passing through an FCC-designated Internet Exchange Point (IXP) and set a daily test period (requiring carriers to conduct tests between 6:00 p.m. and 12:00 a.m. local time) for such tests.”

Anybody have a reference for the “FCC-designated IXPs?”  And what distinguishes them from the actual set of IXPs?

                                -Bill