Comments on NTIA’s proposed Performance Measures for BEAD Last-Mile Networks
Comments on NTIA’s proposed “Performance Measures for BEAD Last-Mile Networks”
From: Karl Auerbach
CEO/CTO InterWorking Labs
Scotts Valley, California
karl@iwl.com (email)
https://iwl.com/ (corporate website)
https://cavebear.com/ (personal website)
Date: November 13, 2024
Permanent URL to these comments: https://www.cavebear.com/cavebear-blog/ntia-bead-dec2024/
Who Am I
I am Karl Auerbach, I am the CEO and CTO of InterWorking Labs (IWL). My CV may be viewed on my website at https://www.cavebear.com/about/karl-cv-long/
I have been involved with the development and deployment of the Internet since 1972.
Our business at IWL ( https://iwl.com/ ) is to create network emulation products that help network developers bench test their code against less-than-perfect network conditions to find problems before their own customers do.
As such, we (and I) deal daily with issues of network imperfections, including latency (including jitter/packet delay variation), bandwidth, packet loss, duplication, out of order packet delivery, and so on.
Overview Of Comments
I appreciate and support the thrust of the BEAD performance measures effort.
However, I find the proposals ambiguous, simplistic, and insufficient. Those inadequacies can be remedied.
My remarks are in four major parts. The first part deals with bandwidth and bandwidth measuring. The second part is similar, but on the topic of latency. The third part is about aspects of network performance that ought to be part of the BEAD Performance Measurement framework. The fourth part is a catch-all of other suggestions.
One point that is made multiple times below is the need for clarity with regard to the point of demarcation between a customer and network provider.