Re: [NNagain] ntia explicitly excludes latency under load from bead measurements

["Livingood, Jason" <jason_livingood@comcast.com>]

>w/a 100ms baseline. Hilarious. Sad.

[SM] This is not all that terrible for minimal RTT measurements, it does however do zilch for latency under load. The 100ms is also not that terrible, given that the US is large, think test point in Anchorage reflector in Miami...

[JL] The 100ms was initially put there to exclude satellite internet from being eligible (prior to LEO operators coming onto the scene). 

[JL] Some concerns I noticed in the document:

1. They want 10% of homes tested in Sec. 3.2, which seems to be an extremely large percentage - well above typical statistical significance - the FCC MBA only needed >30 to be valid nationally. Amusingly, the example they cite in Sec. 3.3 works out to 5% - so they are not internally consistent.
2. In Sec. 3.4, expecting the ISP to temporarily upgrade subs to the highest tier to run tests and then downgrade them again does not make practical sense – for example they suggest that rather than randomly selecting from users in the highest tier that instead you must select from all tiers and then upgrade those not on the highest tier.
3. In Sec. 3.9, it seems a bit too proscriptive on the (IXP) server locations – could be simplified to a regional peering location of the ISP network to allow for flexibility.
4. In Sec. 3.10, similarly proscriptive for example by defining the duration of a test as 10-15 seconds – what if they test can be completed just as accurately in 9 seconds? ISPs should have latitude to configure these tests & the state of the art is moving fast.