Federal Communications Commission

Working Together on Broadband Speed Disclosure for Consumers

April 2nd, 2010 by Peter Bowen - Applications Director, Omnibus Broadband Initiative

Understanding what broadband speeds and performance you will actually experience at home is critical when trying to choose a service or understand what applications and content your service can access once you’re purchased that connection.  The speed you get at home can depend on many things – the speed tier of the service, the degree of congestion on the network, computer processing speeds or multiple devices sharing a connection, to name a few. Including only one factor would be like planning a trip based on just one leg of the journey, even though in the end, the trip’s real time and cost will depend on every leg – a better flight won’t save you money or time if you must travel to an inconvenient airport. The National Broadband Plan focused on the whole picture -- the actual broadband speeds experienced by consumers -- for exactly this reason. What we found was that there is a 40% to 50% gap between the actual speeds that consumers experience and the advertised maximum speeds that ISPs provision.
Recently, the National Cable Telecommunications Association (NCTA) filed comments protesting the data we used from a company called comScore for projecting the average national gap between advertised speeds and actual speeds experienced. Citing to a document prepared by NetForecast, a company hired by Comcast to test usage meters, NCTA complained that the FCC used comScore results as an absolute indicator of individual ISPs’ performance. NCTA noted that because the data doesn’t account for delays caused by a user’s computer, or between client and server, or conflicts from the test traffic itself, and other reasons it did not reflect ISP performance.
Well, exactly. It’s true that the performance gap can be driven by many factors beyond the ISP’s performance – a slow computer, a shared connection, bad internal wiring, or the general vagaries of IP traffic on the Internet, to name a few. But our conclusions weren’t meant as an “absolute indicator” of an ISP’s performance, as NCTA says.  Instead, we were pointing out what a typical consumer actually experiences, no matter the reason. We noted that this gap often creates confusion for consumers, and can make it difficult for them to choose the right provider or speed service tier. Consumers need to know real-world facts to make real-world choices.
Besides, the FCC is, in fact, putting in place testing to measure absolute provider speeds -- an important and related issue, but a separate issue. In 2009 the UK regulator published a report noting that actual speeds delivered by ISP’s were roughly 57% of the advertised speeds and even lower at peak times, and we aim to replicate their approach and make our results available to the public this year. So a few weeks ago, we put out bids, which I blogged about on March 15, to hire a firm to independently test these absolute speeds. We look forward to getting that information..
By the way, providers have had a chance to provide us with more data themselves over the last 6 months. Back in September, we asked providers for better data to refine the comScore analysis – new facts and figures, rather than rhetoric and empty attack. NCTA suggests flaws in the advertised speeds of comScore, but ISPs have and could provide data (in aggregate) on the advertised speeds of their consumers to bolster or refine comScore, Form 477 and other data that the commission relies upon. But no provider has stepped forward.
We have seen increasingly positive signs that all parties – consumer groups, providers and others – are willing to work with the FCC to create standards for disclosure that benefit consumers. Consumers are confused about broadband performance, but if all parties decide to work together, collectively we can solve this problem.

3 Responses to “Working Together on Broadband Speed Disclosure for Consumers”

  1. Shawn Hoy says:

    Spot on, Peter! I remember the requests for data and the responses quite well...crickets.

    The comscore data effectively measured what is was designed to measure: end-user experience. And, if I recall the chart that I made and presented correctly, we also called out network congestion factors that were outside of any ISP's control. We recognized that ISPs should not be held accountable for hardware performance, etc... However, we also recognized that marketing theoretical maximum speeds that are nearly impossible for an actual consumer to achieve, especially at peak usage times, is also not the right answer.

    I look forward to the outcome of the RFP process. That should be a great step forward in the country's ability to measure the actual performance of the network.

  2. Jamion says:

    Excellent, I am glad to see work is being done to promote and provide a better user experience on the net. I am happy with ISP for the most part, but the net speeds are down to what I want to be getting, and honestly what I should be getting. If we can step this up and raise the standards it goes a long way to raising the overall quality of Internet for all users.

  3. Brett Glass says:

    The problem here is that there's no "absolute provider speed." The Internet is a network of networks, and no provider owns them all. Thus, no provider can guarantee speed to anyplace on the Net; it can only make a "best effort" to get data there.

    My ISP is unusual in that it provides users with a guaranteed amount of downstream backbone capacity. But does that help them when Netflix is overloaded, or sends the data from a server that's many hops away, causing jitter? Or when a site uses poor compression and requires more bandwidth than the user has paid for to stream a video without pausing and buffering? Of course not. And the ISP cannot be blamed for this.

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