June 20, Marlene Dortch Secretary Federal Communications Commission th St., SW Washington, DC 20554

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1 Mary L. Henze AT&T Services, Inc. Assistant Vice President th Street, NW, Suite 1000 Federal Regulatory Washington, D.C Phone : mary.henze@att.com June 20, 2016 Marlene Dortch Secretary Federal Communications Commission th St., SW Washington, DC Re: Connect America Fund, WC Docket No Dear Ms. Dortch: On June 16, 2016 Hany Fahmy, Cathy Carpino and the undersigned, all of AT&T Services, Inc. (AT&T), met with Suzanne Yelen, Alex MacDonell, Rodger Woock, Cathy Zima, and Nissa Laughner of the Wireline Competition Bureau. During the meeting AT&T presented a proposal for conducting Connect America Fund Phase II (CAF II) broadband performance testing that we believe meets the framework of the Commission s October 2014 Public Notice (DA ). In addition, AT&T recommended that testing should be conducted over the period of time that reflects actual usage periods of both residential and business customers and that would minimize the impact of testing on the overall customer experience. To meet both its CAF II performance certification requirements as well as broader business needs for measuring network performance, AT&T has begun using a software tool installed on the residential gateway (RG) that is an integral part of receiving Internet access service. No additional CPE is required. The software enables tests to be initiated without customer intervention and measures performance on the network path from the customer premises to testing servers at the Internet edge. This software/rg solution can be used to test all types of broadband technologies (e.g., FTTN, FTTP, fixed wireless) and can be readily programmed to test a random group of customers that can change every year. AT&T explained that it uses software that functions on any RG using a Broadcom chipset, but it noted that since similar software is available for other types of RGs, this proposed solution could be readily replicated by other carriers or made available to smaller providers via the Universal Service Administrative Company. In addition to utilizing a software/rg solution for CAF II testing AT&T also recommended that the Commission adopt a testing timeframe that 1) minimizes the impact of testing on the customer experience and 2) reflects the types of use that deploying broadband into rural areas is intended to support. The 2014 PN proposed an evening-only testing timeframe of 7:00 pm to 11:00 pm but AT&T s internal data indicates that an 18-hour timeframe (6:00 am to midnight) would be more appropriate.

2 All network testing methodologies, by definition, utilize the same network resources available to a customer and thus running the test can degrade the speed, capacity, and/or functionality of the service the customer is experiencing. Moreover, given the statistical multiplexing inherent in broadband services, testing exclusively during a relatively short window could degrade the functionality of the service for other customers. Condensing all testing into a four hour period exacerbates this problem by forcing carriers to do more simultaneous testing regardless of the customer impact. A longer testing timeframe would mitigate this concern while at the same time encompass the multiple usage cycles that are typical of networks serving both business and residential customers and weekday/weekend traffic. The purpose of CAF II is not limited to enabling evening Internet use in rural households. A key goal of deploying broadband deeper into rural America is to enhance educational opportunity and help small and home-based businesses reach national and international markets. AT&T analysis shared during the meeting shows that there is not a single peak period, but rather multiple periods of heavier usage, especially when residential, business, weekday and weekends are all factored in. CAF II recipients must deploy networks capable of meeting the diverse needs of rural customers, both during the day and the night, and an 18-hour timeframe better encompasses this responsibility. All materials used during the meeting are attached. Please feel free to contact me should you have any questions about this matter. Sincerely, /s/ Mary L. Henze Mary L. Henze Attachment cc: S. Yelen A. MacDonell R. Woock C. Zima N. Laugher

3 06/16/2016 CAF II Performance Certification AT&T Proposal Hany Fahmy, Ph.D. Assistant Vice President Global Public Policy External and Legislative Affairs AT&T Intellectual Property. All rights reserved. AT&T, Globe logo, Mobilizing Your World and DIRECTV are registered trademarks and service marks of AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

4 Agenda AT&T CAF II Performance Certification Solution CAF II Performance Measurement Duration AT&T Intellectual Property. All rights reserved. AT&T, Globe logo, Mobilizing Your World and DIRECTV are registered trademarks and service marks of AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

5 Agenda AT&T CAF II Performance Certification Solution CAF II Performance Measurement Duration AT&T Intellectual Property. All rights reserved. AT&T, Globe logo, Mobilizing Your World and DIRECTV are registered trademarks and service marks of AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

6 CAF II Performance Certification: FCC Proposal and High Level AT&T Requirements From FCC s October 2014 Public Notice Proposal (DA ): 50 randomly selected customer location per state Measure hourly during 7-11 pm local time, over four consecutive weeks, once annually 100ms RTT latency Customer location to peering point Certify that the measurements are at or below 100ms RTT and at or above minimum speed AT&T Requirements/Suggestions: Solution/Tool should measure max download speed, max upload speed, latency and packet loss as frequently as hourly. The solution must be able to trigger the testing from the network side without any customer intervention. Thesolutionmustbeabletorunbatchesofautomatedtestsforaslongastwomonths. The solution or tool must not negatively impact the consumer experience for speeds or performance of the service, i.e., a. Speed test should not affect the performance of other subscribers in that area b. Impact on subscriber being measured should be minimal c. Performance measurement should not go against customer monthly data allotment The solution must be developed and implemented sufficiently in advance of the first certification Same solution can be used to certify CAF II implementation over different types of network technologies, i.e., FTTN, FTTP, Fixed Wireless, etc. 4

7 AT&T CAF II Performance Certification Solution -Speed Measurement Tool on the RGagainst Performance Servers Use Software tool on Residential Gateways (RGs) Measure performance against test servers at the Internet edge of AT&T s network Can be used to measure performance on all broadband technologies Different set of randomly selected customers can be used each year Performance Collection Servers Outside Home Copper NID Customer Premise Inside Home RG SW Tool on RG Measurement Device No extra hardware (HW) required for performance certification at the customer premises No customer intervention From the 2015 OIO Transparency Reqs Advisory (GN Docket No ): Internet AT&T IP Core Network Fiber NID GPON ONT RG SW Tool on RG RG 5 SW Tool on Fixed RG Wireless

8 6 Testing Methodology Utilize underlying packet accelerator on the RG to achieve high performance testing with near zero CPU utilization Monitors broadband utilization and runs only during idle time (e.g., below 64kbps) Solution is available on any RG using Broadcom chipset. Similar solutions are available for other RGs Client/Server architecture Server runs on Common Off The Shelf (COTS) HW Client runs on RG Tests can be established for different durations, different packet sizes and different bandwidths A series of test steps are conducted until the throughput can be determined Adaptive testing to adjust test characteristics depending on transport impairments Download/upload throughput, packet loss and latency are reported TR143 based testing can also be used but will not utilize packet accelerator

9 Agenda AT&T CAF II Performance Certification Solutions CAF II Performance Measurement Duration AT&T Intellectual Property. All rights reserved. AT&T, Globe logo, Mobilizing Your World and DIRECTV are registered trademarks and service marks of AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

10 Advantages of 18-hour measurements vs pm CAF II population is a mix of residential and business customers with busy cycles extending far beyond the traditional residential 7-11 pm peak. Our initial analysis shows that there is not a single peak period, but rather multiple periods of heavier usage, especially when factoring in usage from business customers and weekend usage patterns. 6 am-midnight is the best representation of residential/business/weekday/weekend combined duty cycle Per Subscriber Usage-All Speed Tiers Avg. Usage per Sub 3.25GB/Day Avg. Usage per Sub 3.6GB/Day Avg. Usage per Sub 1.74GB/Day Avg. Usage per Sub 1.4GB/Day 8

11 Advantages of 18-hour measurements vs pm An 18-hour certification duration will test the network over that extended window and account for all types of usage. Performance testing can consume significant network capacity and should not be condensed in a 4 hour window. Example: Samknows tests consume a total of 1.7GBs per day at 10Mbps per test subject. For AT&T with 18 states and 50 tests subjects per state, this is a total of 1.5TB at a rate of 9Gbps for 4 hours at the core of the network. From the 2015 OIO Transparency Reqs Advisory (GN Docket No ): AT&T proposal: 50 randomly selected customer locations per state Four measurements a day during four windows over an 18 hour duration (e.g., 6am-10:30am, 10:30am- 3pm, 3pm-7:30pm, 7:30pm-midnight) 100ms RTT latency Customer location to peering point 9

12 10 Presentation title here edit on Slide Master

13 06/16/2016 Backup AT&T Intellectual Property. All rights reserved. AT&T, Globe logo, Mobilizing Your World and DIRECTV are registered trademarks and service marks of AT&T Intellectual Property and/or AT&T affiliated companies. All other marks are the property of their respective owners.

14 Advantages of 18-hour measurements vs pm CAF II population is a mix of residential and business customers with busy cycles extending way beyond the traditional residential 7-11 pm peak. Our initial analysis shows that there is not a single peak period, but rather multiple periods of heavier usage, especially when factoring in usage from business customers and weekend usage patterns. 6 am-midnight is best representation of residential/business/weekday/weekend combined duty cycle Total Usage-12M Speed Tier Overall Avg. Usage per Sub 3GB/Day 12

15 Advantages of 18-hour measurements vs pm CAF II population is a mix of residential and business customers with busy cycles extending way beyond the traditional residential 7-11 pm peak. Our initial analysis shows that there is not a single peak period, but rather multiple periods of heavier usage, especially when factoring in usage from business customers and weekend usage patterns. 6 AM-midnight is best representation of residential/business/weekday/weekend combined duty cycle Hourly % of Traffic. 13