Google, Carriers Disagree on Required Disclosure of Wireless Broadband Speeds

CTIA questioned whether the FCC can get complete, accurate data if it moves forward on a proposal to test mobile broadband speeds. AT&T called measuring the speeds a “daunting task” more difficult than testing fixed connections, as the commission plans to do in a study to be run by SamKnows. Verizon Wireless questioned what would be gained if the FCC “involves itself” in performance testing. But Google encouraged the FCC to push forward, saying accurate information is critical to consumers.

Chief Joel Gurin of the FCC Consumer & Governmental Affairs Bureau announced last month that the commission was looking into whether it should seek mobile throughput data. The FCC sought comment on how to test mobile broadband performance and coverage. Gurin conceded that measuring mobile speeds won’t be easy. But he said the investigation could lead to requirements that providers post speeds similar to the way dealers list average miles per gallon for cars.

"User-generated data is not an appropriate method for measuring wireless broadband speeds given the inherent bias and lack of rigor associated with such data collection,” CTIA warned. “CTIA believes such data would be subject to significant voluntary response bias. Dissatisfied customers are far more likely to test their connections than satisfied customers. The data collected would therefore underestimate overall network performance and fail to reflect actual broadband speeds, making the data of little use to consumers and the FCC.” CTIA also opposed imposing additional data collection and reporting obligations on carriers. If the FCC does move forward, CTIA said, it should convene a technical working group of interested stakeholders “to investigate whether reliable, accurate, and consumer-friendly mobile broadband speed measurements can be collected and reported."

CTIA said the FCC appears to seek to draw comparisons to fixed speeds. “Fixed and wireless broadband have distinct attributes and distinct limitations due to their underlying technologies,” the group said. “Many consumers subscribe to both services to ensure a comprehensive Internet experience."

AT&T said consumers should have an idea of what they're getting when they subscribe to a wireless service. “Today, the most reliable and insightful means for measuring mobile broadband network performance across different providers is ‘drive testing,’ a process by which independent expert firms such as Nielsen and GWS perform various performance tests using devices connected to multiple networks at the same times and locations,” AT&T said.

But AT&T warned that measuring mobile broadband speeds accurately is a huge challenge. “Compared to fixed networks, mobility introduces a greater range of factors that affect performance and those factors are subject to greater variability across different customers,” the carrier said. Signal strength and interference, topography, weather conditions, device capabilities and the movement of end-users “within or between cell sites all present unique challenges in identifying relevant performance metrics and constructing a testing regimen.” AT&T said the FCC should keep in mind that most subscribers today are satisfied with their service and that carriers have invested billions of dollars “deploying technologies designed to provide more robust, higher throughput data services, from 2G technologies like GPRS/EDGE and 1xRTT, to 3G technologies like UMTS and EV-DO, and on to even more capable networks based on HSPA, WiMAX and soon, LTE.”

Verizon Wireless questioned whether the FCC needs to collect data on mobile broadband speeds. “Consumers now can obtain the information they want directly from providers, or through their own ’test drive’ of a mobile broadband device during the trial period offered by providers,” the carrier said. “If the Commission were to consider developing its own data collection efforts, then it should do so only under a comprehensive testing program that collects information through a well-designed test drive procedure that measures multiple metrics affecting service reliability, not just speed."

"Measuring the speed and other network performance metrics of mobile broadband services … is exponentially more challenging than taking similar measurements in the fixed broadband context,” T-Mobile said. Sprint said: “Carriers and third parties are already providing substantial information to consumers … that allow them to make informed choices. Moreover, given the numerous technical difficulties associated with measuring mobile broadband speeds, any Commission program would need to be carefully qualified and could face significant concerns surrounding privacy and network usage.”

"Service providers and independent third parties have generated a wealth of information to help consumers make informed decisions,” said Mobile Future. “The Commission should continue to encourage private sector innovation in consumer-focused applications and tools, rather than imposing regulatory mandates at this time."

Google encouraged the FCC to “collect a diverse range of metrics” for mobile broadband services and make the information widely available. It urged the use of “multiple complementary” methodologies including the “crowdsourcing” criticized by wireless carriers. “Markets rely on information to function properly,” Google said. “Despite the importance of broadband access to our nation, there is a lack of reliable, up-to-date, and readily-accessible information about actual performance of broadband service offerings available in the marketplace today. This is especially true with respect to mobile networks.”