help needed - state of california needs a benchmark

Roy r.engehausen at
Sat Jan 29 13:36:08 CST 2011

On 1/29/2011 10:00 AM, Mike wrote:
> Hello,
>     My company is small clec / broadband provider serving rural 
> communities in northern California, and we are the recipient of a 
> small grant from the state thru our public utilities commission. We 
> went out to 'middle of nowhere' and deployed adsl2+ in fact (chalk one 
> up for the good guys!), and now that we're done, our state puc wants 
> to gather performance data to evaluate the result of our project and 
> ensure we delivered what we said we were going to. Bigger picture, our 
> state is actively attempting to map broadband availability and service 
> levels available and this data will factor into this overall picture, 
> to be used for future grant/loan programs and other support 
> mechanisms, so this really is going to touch every provider who serves 
> end users in the state.
>     The rub is, that they want to legislate that web based 
> '' is the ONLY and MOST AUTHORITATIVE metric that trumps 
> all other considerations and that the provider is %100 at fault and 
> responsible for making fraudulent claims if doesn't 
> agree. No discussion is allowed or permitted about sync rates, packet 
> loss, internet congestion, provider route diversity, end user computer 
> performance problems, far end congestion issues, far end server issues 
> or cpu loading, latency/rtt, or the like. They are going to decide 
> that the quality of any provider service, is solely and exclusively 
> resting on the numbers returned from '' alone, period.
>     All of you in this audience, I think, probably immediately 
> understand the various problems with such an assertion. Its one of 
> these situations where - to the uninitiated - it SEEMS LIKE this is 
> the right way to do this, and it SEEMS LIKE there's some validity to 
> whats going on - but in practice, we engineering types know it's a far 
> different animal and should not be used for real live benchmarking of 
> any kind where there is a demand for statistical validity.
>     My feeling is that - if there is a need for the state to do 
> benchmarking, then it outta be using statistically significant 
> methodologies for same along the same lines as any other benchmark or 
> test done by other government agencies and national standards bodies 
> that are reproducible and dependable. The question is, as a hotbutton 
> issue, how do we go about getting 'the message' across, how do we go 
> about engineering something that could be considered statistically 
> relevant, and most importantly, how do we get this to be accepted by 
> non-technical legislators and regulators?
> Mike-

You took the state's money so you are stuck with their dumb rules.  
Furthermore the CPUC people aren't stupid.  They have highly paid 
consultants as well as professors from colleges in California that are 
advising them.  Unless you have some plan for a very inexpensive 
alternative, don't think you are going to make any headway

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