Don't Let ISPs Hide Poor Performance Behind Averages, Level 3 Asks FCC on Disclosure

Don't let ISPs "hide poor, inconsistent performance" on broadband "behind methodologies that provide a misleading 'average' performance statistic" in disclosure to customers, Level 3 said in an FCC filing on a meeting with officials. "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." Level 3 used a recent Consumer Advisory Committee proposal (see 1511040030) that consumer ISPs report average download speed, upload speed, latency and packet loss as a starting point for its own plan. For ISPs that can measure performance across their interconnections to other networks, Level 3 recommended "calculating average performance for each destination network, and disclosing the average performance for the destination networks with the best, median, and slowest averages." ISPs also should disclose a "Connectivity Rating" showing if "there is a significant likelihood that performance to some parts of the Internet could become degraded during peak hours because of lack of adequate interconnection capacity," said the backbone provider, which has feuded with ISPs and others over interconnection and other Web issues. Its filing posted Friday in docket 14-28 recounted Assistant General Counsel-Federal Affairs Joseph Cavender’s meeting with FCC Chief Technologist Scott Jordan and a officials from the Wireline and Consumer and Governmental Affairs bureaus.