The FCC wants more help in coming up with a definition 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 says there will be more requests for info.
"In this first public notice," said the FCC, "we seek tailored comment on a fundamental question—how the plan should interpret 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 . "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 of 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 FCC.
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 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 others.
This, straight from the FCC, is what they want specific answers to:
"a. the form that a definition of broadband should take;
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 broadband;
e. what segments 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 indicators."
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 thresholds."
And, given the fact that the Internet moves at the speed of Moore's Law on steroids (our characterization, not the FCC's):
"a. what ongoing process should be put in place to update the definition, particularly the threshold levels;
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, 2009 deadline for the switch to digital.
That DTV countdown clock was eventually reset for June 12, but FCC Chairman Julius Genachowski has told B&C that the Feb. 17 broadband plan deadline will be met.