Level 3 may serve as an intermediary between residential consumer service providers and content providers like Netflix (NASDAQ: NFLX), but it has told the FCC that traditional ISPs should provide information to consumers on broadband network performance.
In a recent FCC filing, the service provider said that making information available to consumers on whether they are getting the same user experience as others in their community is important.
"Too few consumers have a real choice for broadband service at their home. But for those who do, disclosures should help them make that choice," said Level 3 in the filing. "Consumers should have access to data that tells them, for each provider, whether the provider offers consistent, high-speed performance to Internet broadly, or whether the provider offers inconsistent performance, with better connectivity to some resources than to others."
Specifically, Level 3 said that ISPs should not be able to hide poor, inconsistent performance behind methodologies that provide a misleading "average" performance statistic.
A key area of focus for Level 3 is interconnection. Level 3 has been establishing a number of new interconnection agreements with Verizon (NYSE: VZ) and Comcast (NASDAQ: CMCSA).
It said that in the event an ISP does not measure across interconnections, consumers should be able to get access to information to determine if they are getting an "FCC-validated" speed to "all or substantially all" of the Internet.
Today, the FCC's Consumer Advisory Committee (CAC) has recommended that ISPs should be measured during the evening peak time period for issues such as download speed, upload speed, latency and packet loss.
Level 3 suggested that besides providing CAC data, all ISPs should be required to report a color-coded "Connectivity Rating." This rating would include three main designations:
Green: Seeing 0-5 events a month, consumers would see that their service performance is rarely impacted by internetworking connectivity issues.
Yellow: Reporting 6-20 events per month, consumers might see its last-mile connection performance impacted to some of their favorite sites impacted occasionally due to internetwork connectivity problems.
Red: With over 21 events a month, consumers should expect that there is a significant likelihood that performance to at least some destinations on the Internet will be impacted by network connectivity problems.
"For ISPs that have the capability to measure performance across their interconnections to other networks, Level 3 recommends calculating average performance for each destination network, and disclosing the average performance for the destination networks with the best, median, and slowest averages," Level 3 said. "That will help ensure consumers are not misled by reported "average" performance figures that mask significant variations in actual performance to different parts of the Internet."
Providing access to real-world performance of sites across interconnections will enable consumers to compare broadband service options from telcos and cable operators.
- see the FCC filing (PDF)
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