Broadband Labels Speed and Latency Validation Policy
- Introduction
This Broadband Labels Speed and Latency Validation Policy (Policy) outlines Alma Telephone Company, INC.’s (ATC) speed and latency validation policy in compliance with the broadband labels regulations adopted by the Federal Communications Commission (FCC) on November 14, 2022.
- Purpose
The purpose of this Policy is to establish clear guidelines and procedures for testing and validating broadband speed and latency measurements. By adhering to this Policy, ATC aims to provide customers and the FCC with accurate information about the performance data on its broadband labels.
- Performance Standards
ATC will list the typical upload and download speeds and typical latency for fixed (wireline) broadband services on each broadband label.
- Typical Upload and Download Speeds: ATC will disclose typical upload and download speeds measured in megabits per second, or Mbps, for each standalone broadband service tier. These speeds represent the typical performance that customers can expect under normal operating conditions. ATC may reduce speeds after a customer has exhausted their speed data allowance on applicable plans.
- Typical Latency: ATC will disclose typical latency metrics measured in milliseconds, or ms, for each standalone broadband service tier.
- Testing and Validation Procedures
ATC’s broadband label testing methods adhere to industry standards and FCC guidelines to ensure accuracy and consistency in reporting.
- Methodology: ATC will conduct manual internal testing utilizing the embedded performance tools available on Calix Gigaspire ONTs across a random sample of active broadband subscribers. Upload, download and latency tests will be performed manually and results recorded.
- Frequency of Testing: The VP of Network Operations will direct the testing each time ATC generates a new broadband label. The Director of Marketing will generate a new broadband label when there are any changes to an existing label or for any new standalone broadband service offered for purchase to customers.
- Documentation: After testing, the VP of Network Operations will document the service plan’s speed and latency test results using the sample data collection form provided in the Appendix. The VP of Engineering will email the results to the Director of Marketing. The Director of Marketing will incorporate the data into the appropriate broadband label and maintain these records according to the archive requirements outlined below in Section VI.
- Employee Training: ATC will annually train responsible employees who conduct broadband label speed and latency testing on the testing procedures outlined in this Policy.
- Appendix
Appendix A: Wireline Network Performance Metrics Establishment Procedure provided as part of this Policy offers detailed information about the methodology, equipment, software, and testing locations ATC uses for measuring speed and latency.
- Archive of Test Results
The VP of Network Operations will retain the speed and latency test results with the relevant broadband label for record-keeping purposes. ATC will archive labels and speed and latency test results in a folder named Broadband Labels on the Network share.
ATC will archive the labels and speed and latency test results for at least two (2) years after the service plan is no longer offered to new customers and the label is no longer displayed at the point of sale. Upon request, the VP of Network Operations will provide any archived label, evidence sufficient to support the accuracy of the labels’ content, including speed test results, and this Policy to the FCC within thirty (30) days.
- Review and Revision
The VP of Network Operations will periodically review this Broadband Speed and Latency Validation Policy and make any necessary revisions to ensure its effectiveness and compliance with evolving FCC regulations, industry standards, and technological advancements. The VP of Network Operations will document changes to this Policy by updating Attachment A
Attachment A
Record of Broadband Speed and Latency Validation Policy Changes
This section describes changes made to the Policy.
| Policy Section | Date | Description | Employee Name |
Appendix A
Wireline Network Performance Metrics Establishment Procedure
- Introduction
This document details the broadband labels testing procedure for wireline broadband technologies and defines key network performance metrics used to label broadband services that ATC provides to customers.
This procedure covers the following technologies:
- Wireline
- Cable
- Fiber
The testing will analyze the following metrics:
- Download Throughput
- Upload Throughput
- Latency
- Equipment / Software
The testing will use the following current and capable equipment:
Testing Hardware and Software
- Calix Gigaspire ONT’s via the Calix Support Cloud performance testing application
Network Application and Software
- Speedtest.net
ATC will endeavor to use the internally deployed Ookla test server to ensure consistency and accuracy of results and minimize the impact of factors outside ATC’s control. Where the on-net Ookla speedtest server is not available, ATC will use the nearest geographically located speedtest server on the Speedtest.net network.
- Testing Locations and Procedure
Locations
For wireline technologies, ATC will test a random sample of active customers across all offerings. This will consist of accessing the customer’s Gigaspire unit via the Calix Support Cloud application and performing the speed test and latency test.
Servers are located in the following areas:
- Local Ookla test server located in the Alma, GA Central Office
- Next nearest test location on the Speedtest.net network
Procedure
For each technology, ATC will complete five (5) speed tests via the speed test application for each selected customer location, not to exceed 10 locations per technology and speed offering. ATC will average the results of the five (5) speed tests to identify service levels.
For Wireline:
- Access the customer’s Calix Gigaspire utilizing the Calix Support Cloud Application.
- Select the Service Module in the Calix Support Cloud Application.
- Review current data usage to ensure customer utilization will not impact the test.
- Run the speed and latency tests five (5) times at 1-minute intervals and log the results using the sample data collection form below, as well as screen capture the results.
Should throughput or latency results vary by more than 15% from one test to another or from the anticipated plan characteristics, ATC will halt performance metrics to troubleshoot any potential network or test device issues. Once staff clears any potential issues, staff will restart the process from the beginning.
- Testing Results
ATC will summarize test results using a copy of the table below:
Employee Name:
Date:
Time:
Technology:
Plan Name:
Speedtest (Ookla or Fast.com):
Test Location:
| Test | DL (Mbps) | UL (Mbps) | Latency (ms) |
| Test #1 | |||
| Test #2 | |||
| Test #3 | |||
| Test #4 | |||
| Test #5 | |||
| Average |
For Wireline technologies, ATC will compute the broadband label’s final value by averaging the test results staff conducted at a single location.
- Plans
This procedure covers ATC’s current standalone wireline broadband plans archived in the folder labeled Broadband Labels on the shared Networking drive.