RE: FCC Takes Steps to Enforce Quality Standards for Rural Broadband

[Frank Bulk]

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  On Behalf Of Bill Woodcock
Sent: Thursday, October 31, 2019 10:56 PM
To: Sean Donelan ; North American Network Operators' Group 

Subject: Re: FCC Takes Steps to Enforce Quality Standards for Rural Broadband

 






On Oct 31, 2019, at 6:42 PM, Sean Donelan mailto:s...@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

 

RE: FCC Takes Steps to Enforce Quality Standards for Rural Broadband

[Aaron Gould]

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.

 

-Aaron

 

From: NANOG [mailto:nanog-boun...@nanog.org] On Behalf Of Livingood, Jason
Sent: Monday, November 4, 2019 1:23 PM
To: Bill Woodcock; North American Network Operators' Group
Subject: Re: FCC Takes Steps to Enforce Quality Standards for Rural Broadband

 

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. 

 

Jason

 

 

 

From: NANOG  on behalf of Bill Woodcock 
Date: Thursday, October 31, 2019 at 11:58 PM
To: Sean Donelan , North American Network Operators' Group 

Subject: Re: FCC Takes Steps to Enforce Quality Standards for Rural Broadband

 





On Oct 31, 2019, at 6:42 PM, Sean Donelan  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

 

Re: FCC Takes Steps to Enforce Quality Standards for Rural Broadband

[Livingood, Jason]

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.

Jason


From: NANOG  on behalf of Bill Woodcock 
Date: Thursday, October 31, 2019 at 11:58 PM
To: Sean Donelan , North American Network Operators' Group 

Subject: Re: FCC Takes Steps to Enforce Quality Standards for Rural Broadband




On Oct 31, 2019, at 6:42 PM, Sean Donelan 
mailto:s...@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

Re: FCC Takes Steps to Enforce Quality Standards for Rural Broadband

[Bill Woodcock]

> On Oct 31, 2019, at 6:42 PM, Sean Donelan  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



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Re: FCC Takes Steps to Enforce Quality Standards for Rural Broadband

[Bill Woodcock]

> On Nov 1, 2019, at 12:37 AM, Jim  wrote:
> 
> On Thu, Oct 31, 2019 at 1:08 PM Jeff Shultz  wrote:
>> 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...
> 
> It sounds like there would be some test method concerns there by
> having merely one performance-testing server.

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.

-Bill



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Re: FCC Takes Steps to Enforce Quality Standards for Rural Broadband

[Jim]

On Thu, Oct 31, 2019 at 1:08 PM Jeff Shultz  wrote:
>[snip]
> 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.

> --
> Jeff Shultz
--
-JH

Re: FCC Takes Steps to Enforce Quality Standards for Rural Broadband

[Jeff Shultz]

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
level."

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

On Thu, Oct 31, 2019 at 10:44 AM Sean Donelan  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
>
> Description:
> 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.



-- 
Jeff Shultz

-- 
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