Today, the Network Neutrality rules go into effect for service providers in the United States. Much of the attention is focused on the “Bright Line” rules that were established and the Title 2 provisions, there was another fascinating part of the ruling that was not highlighted as much as it should have been.
“With respect to network performance, we adopt the following enhancements:
- The existing transparency rule requires disclosure of actual network performance. In adopting that requirement, the Commission mentioned speed and latency as two key measures. Today we include packet loss as a necessary part of the network performance disclosure. [Emphasis added]
- We expect that disclosures to consumers of actual network performance data should be reasonably related to the performance the consumer would likely experience in the geographic area in which the consumer is purchasing service. [Emphasis added]
- We also expect that network performance will be measured in terms of average performance over a reasonable period of time and during times of peak usage. [Emphasis added]
- We clarify that, for mobile broadband providers, the obligation in the existing transparency rule to disclose network performance information for “each broadband service” refers to separate disclosures for services with each technology (e.g., 3G and 4G). Furthermore, with the exception of small providers, mobile broadband providers today can be expected to have access to reliable actual data on performance of their networks representative of the geographic area in which the consumer is purchasing service—through their own or third-party testing—that would be the source of the disclosure. 410 Commission staff also continue to refine the mobile MBA program, which could at the appropriate time be declared a safe harbor for mobile broadband providers.” [Emphasis added]
This is from page 73-74 of FCC-15-24A1 – which is the official FCC document on network neutrality, and the above section is - to me at least – one of the most critical part of the announcement for subscribers. Taken outside the financial aspect of the bright line rules to protect the “free” aspect of the Internet, the section above highlights a growing problem for consumers with broadband services.
Speed is not always a good indicator of service.
Earlier this week Procera launched a solution called ScoreCard. We started developing this a long time before the FCC published these rules. We initiated the development of this solution because we believed that subscribers today do not have a good measurement of how their broadband service will react with the applications that they care about.
The most common methodology used today is to run a spot speed test on the network to see the performance for that instant in time, or to use active monitoring solutions that run periodic tests and report the results from specific devices or network locations. They report latency of ping tests and the upload and download speed at that instant in time.
If you read the above section, that method of measurement does not meet the FCC’s requirement for “a reasonable period of time and during times of peak usage”. It also does not add packet loss as a measurement either.
Many consumers don’t realize that speed is not always a guarantee of quality. If you are surfing the web, playing games, or using Skype, high latency and packet loss (regardless of the network performance) will degrade your service. Ask any real-time gamer that has suffered from lag how bad it is to have high latency – they get fragged constantly in shooters. Ask any Skype user what happens when the latency is high or packet loss occurs – you talk over your caller and you stutter.
ScoreCard makes it simple for consumers and operators. It measures all traffic for all subscribers all of the time, and then displays a score based on the actual performance of the network from the peak usage time for wherever the subscriber is (or in the case of mobile networks – was) during the interval selected. It grades the service just like you saw in school – from A to F – for a range of application types as shown below.
We didn’t design ScoreCard for network neutrality. We designed it for subscribers. It just happens to line up that our definition of the subscriber experience happens to match exactly with what the FCC wants to see broadband operators measure for subscribers. As a consumer, I would love to select my service based upon how it delivers real applications.