FCC Seeks More Help In Defining Broadband


The FCC wants more help in coming up with a definition, or
multiple definitions, of broadband and other elements of its national broadband
plan, saying it must seek additional, "tailored" comments. It also
wants them ASAP. The comment deadline is Aug. 31, with replies due Sept. 8.

The commission released a public notice Thursday seeking
more comments on just how to define broadband, focusing on what speed of
Internet access would fill that bill, and suggests there will be more
requests to come.

"In this first Public Notice," said the FCC,
"we seek tailored comment on a fundamental question-how the Plan
shouldinterpret the term "broadband" as used in the Recovery Act, recognizing
that our interpretation of the term as used in that statute may inform our
interpretation of the term in other contexts."

The commission already asked the question broadly in its
notice of inquiry on the national broadband plan, for which it has already
received comments and reply comments.

But FCC broadband Czar Blair Levin has said publicly that he
was disappointed in those initial comments. The new round of comments is part
of what the FCC calls a "pleading cycle." That is particularly
appropriate since Levin literally pleaded for more and better input.

Blair Levin

"In light of the record received in response to the National Broadband
Plan Notice of Inquiry and the discussions at the workshops that have been held
to date," said the commission notice, "we recognize that we must seek
additional, focused comment on certain specific topics."

The commission said Thursday it wants more specific comment
on what specifically defines a "minimum threshhold" of broadband
service, and how that threshhold would be updated going forward.

The National Telecommunications & Information
Administration has already come up with a definition for broadband for its stimulus
grant program, which the FCC advised on. But then-FCC Chairman Michael Copps
made it clear that would not necessarily be the same definition adopted by the

For the record, that definition is: "Data transmission
technology that provides two-way data transmission to and from the Internet
with advertised speeds of at least 768 kilobits per second (kbps) downstream
and at least 200 kbps upstream to end users, or providing sufficient capacity
in a middle mile project to support the provision of broadband service to end
users within the project area."

The FCC is looking for a more precise definition, pointing
out that upload and download speed (it uses the term "throughput")
can vary from advertised to actual, or depending on what the end point for
measurement is. In addition, the notice says, there are issues including
latency, reliability and mobility that may be relevant in some cases and not in

This, straight from the FCC, is what they want specific
answers to:

"a. the form that a definition of broadband should

b. whether to develop a single definition, or multiple definitions;

c. whether an application-based approach to defining broadband would work, and
how such an

approach could be expressed in terms of performance indicators;

d. the key characteristics and specific performance indicators that should be
used to define


e. what segment(s) of the network each performance indicator should measure,
such as the local

access link to the end user, or an end-to-end path;

f. how factors such as latency, jitter, traffic loading, diurnal patterns,
reliability, and mobility should

specifically be taken into account;

g. whether different performance indicators or definitions should be developed
based on

technological or other distinctions, such as mobility or the provision of the
service over a wired or

wireless network;

h. the feasibility and verifiability of measuring different performance

as well as:

"a. what minimum thresholds should be assigned to the
performance indicators;

b. the minimum thresholds necessary for broad classes of applications to
function properly;

c. whether we should adopt multiple, escalating tiers of minimum

And, given the fact that the Internet moves at the speed of Moore's law on steriods
(our characterization, not the FCC's):

"a. what ongoing process should be put in place to
update the definition, particularly the threshold


b. how often should such updates should occur;

c. what criteria should be used to adjust thresholds over time;

d. how modifications over time to the definition will affect the Commission's
ability to collect and

publish meaningful data on broadband deployment and adoption."

And in case anyone missed Levin's point about wanting more
specific, on point, info, the commission ended with this advisory in bold type:
"we strongly encourage parties to develop responses to this Notice that
adhere to the organization and structure of the questions in this Notice."

The FCC has to come up with the plan by Feb. 17, 2010 per
instructions from Congress. The FCC's blog has
even instituted a countdown clock, which the commission also did for its other
notable congressionally-mandated Feb. 17 deadline--for the switch to digital.

That DTV countdown clock was eventually reset for June 12,
but FCC Chairman Julius Genachowski has told Multichannel.com that the Feb. 17
broadband plan deadline will be met.