FCC Takes Steps to Enforce Quality Standards for Rural Broadband

There is just so much I want to make sarcastic comments about, but I worry about offending future potential employers (all of them).


FCC Takes Steps To Enforce Quality Standards For Rural Broadband Networks and Also Provides Additional Flexibility to Reduce Burden on Companies


In response to Petitions for Reconsideration and Applications for Review of an earlier bureau- level Performance Measure Order, the FCC today maintained the existing requirement that carriers conduct quarterly speed and latency tests between specified numbers of active subscribers� homes and the Internet, and made targeted modifications to the testing procedures, including:

- Modifying the schedule for commencing testing by basing it on the deployment obligations specific to each Connect America Fund support mechanism;

- Implementing a new pre-testing period that will allow carriers to become familiar with testing procedures without facing a loss of support for failure to meet the requirements;

- Allowing greater flexibility to carriers in identifying which customer locations should be tested and selecting the endpoints for testing broadband connections.

As someone working for one of those Rural Broadband providers, this
has been of more than passing interest. What will show up when the
testing commences will be interesting.
What has most people (from anecdotal observation) concerned is that we
are usually more than one or two carriers out from an IXP where the
speed test server will be, and don't have a lot of influence on paths
and carriers that we aren't directly connected with.

The basic premise makes sense - "We're paying you federal tax monies
to provide a certain level of service or better to these areas - you
ought to be able to demonstrate that you are providing service to that

It's the mechanics that tend to get people tied up in knots.

What has most people (from anecdotal observation) concerned is that we
are usually more than one or two carriers out from an IXP where the
speed test server will be, and don't have a lot of influence on paths
and carriers that we aren't directly connected with.

It sounds like there would be some test method concerns there by
having merely one performance-testing server.

But the performance of "broadband service" is really end to end;
the choice of direct carrier, their routing policies, and indirect carriers,
is still an integral part of the service that should be measured ---
the best last mile connection possible has no value if the provider is
allowed to mess that up by undersizing peering or backhaul, whether
directly, or indirectly through carriers which end-to-end traffic depends upon.

Seems like a testing method might have a plethora of speed testing servers
and include HTTPS bandwidth tests through websites fronted by numerous
CDN nodes which are by design indistinguishable from regular traffic.

Given enough varying remote test locations and a large enough number
of samples over time, and providers prevented from being able to
distinguish what traffic or users might be test traffic or test users and
which users or traffic might be normal traffic; It seems like they ought
be able to formulate an automatic analysis of the data that will limit the
affect of "noise" such as one-off suboptimal routing to some destinations,
involving one IXP, etc.

IXPs are the only useful place to put bandwidth-test servers. Downstream from an IXP and you don’t measure the relevant portion of the path. Through an IXP, and you’re testing the combination of your own transit, and the irrelevant and coincidental transit of the bandwidth test server, not your own.


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


I do not. But in the FCC’s Measuring Broadband America program (MBA) they have SamKnows measurement servers located in a few places so perhaps that is what they mean? See https://www.fcc.gov/reports-research/reports/measuring-broadband-america/measuring-fixed-broadband-eighth-report which says “The measurement servers were hosted by M-Lab and Level 3 Communications, and were located in ten cities across the United States near a point of interconnection between the ISP’s network and the network on which the measurement server resided.” In the newest (in process) report I believe they also added StackPath.


I heard that we would be testing to Dallas or something like that from my ISP in San Antonio.

I think I heard that customer CPE routers will soon have that testing functionality built into them.


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.