Commenters Dispute Need for Standardized Broadband Speed Testing

Fine Point’s claims that current testing protocols “misrepresent actual user experience” and “distort competition” are “dubious,” USTelecom said. The FCC’s 2018 and 2019 performance testing rules are also “well-settled and the result of extensive Commission proceedings,” the group said: “There is absolutely no reason to change course now.” Changes “would create unnecessary burdens and costs” for providers, the commission and the Universal Service Administrative Co., “which have all already invested heavily in standing up testing based on the current rules.”

NCTA urged the FCC not to respond to the petition. Fine Points wants “a set of highly prescriptive rules governing the measurement process,” cablers said: “The intent of such a regime would be to eliminate the use of measurement solutions that are tied to the use of particular network equipment.” In addition, NCTA said Fine Point’s petition lacks the necessary evidence to justify a rulemaking proceeding. “While the benefits of Fine Point’s proposal are speculative, it is certain that a new mandatory regime along the lines proposed would be highly disruptive and burdensome to thousands of broadband providers that are subject to the Commission’s rules.”

The commission's rules are “designed to promote transparency and enable consumers to comparison-shop for broadband service,” WISPA said. “Fine Point has failed to explain how the existing broadband label rules are somehow ineffective in providing consumers with information they need to choose their broadband service provider and that new rules are necessary.” In the short time period broadband label rules have been in effect, “the Commission has not reported any cases showing that broadband providers are not displaying the required information.”

Ookla, which tracks connection data, also raised concerns. Fine Point suggests that rules could be based on the Broadband Forum’s TR-143 standard, the company said. “But TR-143 is not well-suited for the sorts of testing required by FCC rules, and adopting it would not meet the variety of testing needs of the diverse array of broadband subsidy programs, services, and providers currently available to Americans,” Ookla said: “TR-143 cannot scale to meet the demanding FCC performance testing requirements. Most notably, it provides a narrow perspective by relying solely on individual fixed [consumer premises equipment] measurements, which are inadequate for comprehensive evaluations of both fixed and mobile broadband performance.”