Broadband Labels Speed and Latency Validation Policy

Introduction

This Broadband Labels Speed and Latency Validation Policy (Policy) outlines Little Miami Gig’s (LMGig) 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, LMGig aims to provide customers and the FCC with accurate information about the performance data on its broadband labels.

Performance Standards

LMGig 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

LMGig 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. LMGig may reduce speeds after a customer has exhausted their speed data allowance on applicable plans.

Typical Latency: LMGig will disclose typical latency metrics measured in milliseconds, or ms, for each standalone broadband service tier.

Testing and Validation Procedures

LMGig’s broadband label testing methods adhere to industry standards and FCC guidelines to ensure accuracy and consistency in reporting.

Methodology: LMGig will conduct manual internal testing utilizing the embedded performance tools available across a random sample of active broadband subscribers. Upload, download and latency tests will be performed manually and results recorded.

Frequency of Testing: The Director of Network Operations will direct the testing each time LMGig 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 Director 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 Director of Operations 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: LMGig 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 LMGig uses for measuring speed and latency.

Archive of Test Results

The Director of Network Operations will retain the speed and latency test results with the relevant broadband label for record-keeping purposes. LMGig will archive labels and speed and latency test results in a folder named Broadband Labels on the Network share.

LMGig 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 Director 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 Director 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 Director 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 technologies and defines key network performance metrics used to label broadband services that LMGig 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

• Customer-provided routers via cloud platform application for testing application

Network Application and Software

• Speedtest.net

LMGig will endeavor to use the internally deployed test server to ensure consistency and accuracy of results and minimize the impact of factors outside LMGig’s control. Where the on-net speedtest server is not available, LMGig will use the nearest geographically located speedtest server on the Speedtest.net network.

Testing Locations and Procedure

Locations

For fiber optic technologies, LMGig will test a random sample of active customers across all offerings. This will consist of accessing the customer-provided routers via cloud platform application for performing the speed and latency test. 

Servers are in the following areas:

• Local test server located in central Ohio  

Procedure

For each technology, LMGig 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. LMGig will average the results of the five (5) speed tests to identify service levels.

For Wireline:

• Access customer-provided routers via cloud platform application.
• Select the device to test via cloud platform 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, LMGig 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

LMGig will summarize test results using a copy of the table below:

Employee Name:

Date:

Time:

Technology:

Plan Name:

Speedtest:

Test Location:

For wireline technologies, LMGig will compute the broadband label’s final value by averaging the test results staff conducted at a single location.

Plans

This procedure covers LMGig’s current standalone wireline plans archived in the folder labeled Broadband Labels on the shared Networking drive.