100 Millisecond Latency a Bad Yardstick for CAF Quality, ViaSat Says

The FCC Connect America Fund Phase II build-out should look at an alternative set of eligibility requirements that allow for different technology platforms, minimize the contribution asked of end users and still provide service capable of such broadband applications as video streaming, ViaSat said in a filing posted Monday in docket 10-90. Those proposed requirements include speeds of 25 Mbps downstream and 3 Mbps upstream, since speed is a far more important factor to quality of service than such issues as latency and jitter, ViaSat said. It also recommended a voice service with a mean opinion score of four, MOS being a better measure than latency of perceived quality, ViaSat said. And those requirements also should add service plans with usage allowances to the FCC's urban rate survey results, packet loss of no more than 0.01 percent and average one-way jitter of at most 30 milliseconds for interactive, real-time applications, ViaSat said. It responded to back-and-forth filings by Adtran and Hughes Network Systems about CAF standards (see 1507280024). While agreeing with Hughes that standards shouldn't be so firm as to preclude any type of technology out of hand, ViaSat agreed with Adtran that Hughes' proposed satellite-specific alternative standards could mean a "second class" broadband. The 100 milliseconds latency requirement in CAF Phase I "effectively 'boxed out' ... satellite broadband providers that use geostationary spacecraft," ViaSat said. Its own set of proposed alternate criteria, meanwhile, would meet CAF objectives better than a 100 millisecond latency requirement because they would ensure high-quality broadband and voice services while also allowing competition among an array of technologies and providers, ViaSat said. If the FCC keeps the 100 millisecond yardstick, it should make it clear that applies only to latency-sensitive traffic, the company said. "Low latency has little bearing on the end-user experience with respect to video streaming, which now accounts for most peak downstream traffic." ViaSat said having one latency benchmark even for nonlatency-sensitive traffic would make network operators "forgo the advantages of higher speeds offered by geostationary satellite technologies with no offsetting benefits in terms of user experience."