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Help the FCC Craft A Realistic Broadband Policy

Phillip Dampier June 8, 2009 Editorial & Site News, Net Neutrality, Public Policy & Gov't 15 Comments

The Federal Communications Commission is accepting comments from citizens until July 8, 2009 as they craft a national broadband plan.  Free Press’ Save the Internet campaign has made sending our comments a lot easier for you and I.  They’ve created an online form that directly interfaces with the FCC’s formal comment submission system.  They have pre-filled a sample message to send to the Commission for consideration, but I strongly recommend you write one of your own.  Net Neutrality is a critically important issue for Stop the Cap!, but there is room to also share your thoughts on usage caps, metered pricing, competition and oversight — all of the issues we focus on regularly here.

They are already hearing from special interests and lobbyists attempting to influence the Commission into creating a broadband policy that caters to the whims of commercial interests.  It is paramount that the Internet first and foremost serve the interests of the people.

For the first time in a long time, every citizen can have a voice heard by anyone who wants to listen.  The impact and importance of that voice is judged on the merit of the message, not on how much money, power or influence that person has to present it.  Net Neutrality rules enforced as part of a national broadband policy protects your voice, your ideas, and your participation in our democracy.  Some commercial interests seek a net where their voices can travel faster, their partners get preferential treatment, and everyone else risks being throttled, capped, metered, or impeded.

Gordon F. Snyder, Director of the National Center for Information and Communications Technologies

Gordon F. Snyder, Director of the National Center for Information and Communications Technologies

Without Net Neutrality protections, the Internet may find itself resembling broadcasting in this country, where a few powerful interests control the medium, the message, and the content.  No company should be making these choices for you, either through speed throttling or imposing limits or meters on those products and services that aren’t owned, controlled, or partnered with that provider.  Your ISP should not have the right to impose a broadband strategy that is designed to protect the business model of another product or service they happen to offer, such is the case with online video.

Tell the FCC you don’t want to settle for a national broadband policy that doesn’t make America #1.  That means:

  • The fastest possible speeds, not rationed “fast enough for most people to check e-mail and web pages broadband.”
  • An end to policies that allow providers to artificially limit consumption through throttles, usage caps, and forced metered pricing at enormous markups.
  • Protections against manipulating broadband policies to protect providers’ other business interests, such as streaming online video competing with traditional cable television business models.
  • Policies that encourage competition among providers, even if it means establishing “common carrier” status to permit competitor access to wired infrastructure under fair terms.
  • A policy that recognizes the rapid development of broadband technology and expects providers to grow with the times to accommodate new platforms, technologies, and applications.
  • A policy that embraces municipal, public, and/or non-profit organizations that wish to establish advanced networks as they see fit, without having to face lawsuits and delay tactics from commercial interests.
  • Recognition that there cannot be two broadband platforms in this country – one slow lane for rural and under-competitive markets and one fast lane for urban areas.  Equal access.  Equal speeds.  Fair pricing.

Gordon F. Snyder, Director of the National Center for Information and Communications Technologies, provides additional insight in his blog, and should be considered when writing your suggestions to the FCC:


On Defining Broadband Capability:

Broadband is defined lots of different ways and the FCC is seeking comment on how the FCC should define broadband capability, including how to take into account the various existing and emerging technologies.

The FCC currently uses the terms advanced telecommunications capability, broadband, and high-speed Internet. Most of us think of broadband as data – high speed data but just data. That’s changing for many of us – we’re in the middle of the migration to all IP networks and I believe voice and video must be included along with data in the new broadband definition. I’d be fine with just calling it just broadband.

We’re also dealing with a wide range of technologies – Fiber To The Home (FTTH), Fiber To The Node (FTTN), WiMAX, LTE, DOCSIS, ADSL, etc. Each of these provides a different range of bandwidths depending on distance, signal strength, etc. I’d like to see specific bandwidth ranges that can be easily adjusted as we ramp up speeds. I also believe we need to define both upstream and downstream bandwidths for these ranges. Here’s the way the FCC started defining bandwidth tiers of service last year:

First Generation data: 200 Kbps up to 768 Kbps
Basic Broadband : 768 Kbps to 1.5 Mbps
1.5 Mbps to 3.0 Mbps
3.0 Mbps to 6.0 Mbps
6.0 Mbps and above

I’d like to see these tiers broken out further and include separate listings for upstream and downstream bandwidths. I’d also like to see average speeds calculated over the course of 24 hour/7 day a week periods be listed. It makes no sense for my provider to list maximum speeds that I can only get at 3 in the morning when all of my neighbors are sleeping.

In addition, these tier levels must be dynamic and adjust up with technology improvements. I hope I’m not still sitting at the 3-6 Mbps tier (in one direction) a year from now.

I don’t believe there should be different definitions or standards for the type of broadband service provided. For example, we don’t need separate definitions for mobile broadband services (e.g. wireless) and fixed broadband services (e.g. cable modem). Bandwidth is bandwidth so keep them all the same.

I also don’t believe rural and other hard to get to areas should have lower tier standards and definitions. We must make every effort to provide equal service to as many people as possible in our country.

On Defining Access:

Broadband capability needs to be everywhere. Prioritizing (for example, saying a library requires more bandwidth per user than a home) makes little sense. We need to make broadband available to everyone.

Competition is key if we want bandwidths from different providers to leapfrog and prices to drop. In Massachusetts we’ve seen fierce competition in the eastern part of the state as Verizon (FiOS) and the cable companies go back and forth with each other. In Western Massachusetts (where I live) FiOS is not available and we are seeing little competition when compared.

Areas where there is only a single provider typically have to wait for long periods of time to see new broadband delivery technologies. More competition in under-served areas is critical areas or these areas will continue to fall further behind. I’d like to see the national broadband plan focus stimulus money on these areas with limited competition and capability.

How should the Commission consider the different qualitative features discussed in the definition of broadband, such as latency, peak download speed, and mobility? We must set these features aggressively and at a level that does not just compete but leads the rest of the world – this must be our goal. The OECD maintains a portal that provides access to a range of broadband-related statistics gathered by the OECD. The OECD has indentified five main categories which are important for assessing broadband markets – Penetration, Usage, Coverage, Prices, and Service & Speeds. For example, fiber is the dominant connection technology in Korea and Japan and now accounts for 48% of all Japanese broadband subscriptions and 43% in Korea. With fiber comes lower latency, higher peak download speeds and (yes) even more mobility.

The FCC also seeks comment on the extent to which access hinges on affordability.  Simply put, it needs to be fast and it needs to be cheap. Referring to the OECD portal again and as an example, on average, subscribers in OECD countries pay 15 times more per advertised megabit of connectivity than Koreans. We must be faster and cheaper than Korea if we want to compete with the rest of the world.

The FCC seeks comment on what it means for a person with disabilities to “have access” to broadband capabilities.  The report references the Assistive Technologies Act of 2004, supporting state efforts to improve provision of assistive technology to individuals with disabilities; the Americans with Disabilities Act of 1990,requiring common carriers to provide telecommunications relay services for deaf and speech-impaired individuals; and the Amendment of the Commission’s Rules Governing Hearing Aid-Compatible Mobile Handsets; Petition of American National Standards Institute Accredited Standards Committee C63, that focuses on adopting hearing aid compatibility requirements for mobile wireless devices.

Higher bandwidths and lower costs per megabit will drive innovation and applications that help and support people with disabilities. That said, assistive technologies must continue to be regulated and ratcheted up as bandwidth and access continues to improve.

I believe residential broadband (to the home) is key in our country. Homes in our broadband equation are the lowest common denominator. Lots of inexpensive and reliable bandwidth to everyone’s home will drive bandwidth up and cost down at work, libraries, public Wi-Fi hotspots, etc. We must set our residential broadband bar higher than the rest of the world in each of the five OECD portal categories.

I highly recommend reviewing Gordon’s insights on the FCC’s broadband policy development because, thus far, I’ve found myself in complete agreement.

Currently there are 15 comments on this Article:

  1. I didn’t know there was a site like this pushing to stop caps. I’ll keep myself in the loop with you guys and head over to fill out that form.

  2. Smith6612 says:

    I’ll certainly see about writing to the FCC about this internet plan, and I’m glad they’re being open about it. Seeing this, I wonder how the results would turn out even from the most basic users as well.

  3. KP says:

    Not being as technically savvy as most contributors to this site, I assume that upstream and downstream actually have the meanings I think they have. I’d appreciate someone providing an elementary explanation of the difference between them regarding bandwidth. I would previously have thought that a given pipe would support the same bandwidth in either direction.

    Thanks.

    • There are two types of networks in this regard: synchronous, which deliver the same “upload/upstream” speed as “download/downstream,” and the far-more-common asynchronous, which almost always delivers considerably faster download speed than upload speed.

      At the moment, almost all DSL from phone companies and cable broadband from the cable company employ asynchronous service. You’ll see us often reference speeds on this site like this: 15Mbps/1Mbps or 7Mbps/768kbps. That means your download speed is 15Mbps and your upload speed is 1Mbps. The second example illustrates more common speeds experienced by DSL customer – 7Mbps for downloading, but only 768kbps for upload.

      Data transfer speed:

      * 1 kbps = 1,000 bits per second
      * 1 Mbps = 1,000,000 bits per second.
      * 1 Gbps = 1,000,000,000 bits per second.

      kbps (kilobits/sec) means thousands of bits per second
      mbps or Mbps (megabits/sec) means millions of bits per second
      gbps or Gbps (gigabits/sec) means billions of bits per second (where “billion”= 1,000,000,000.00″)
      tbps (terabits/sec) means trillions of bits per second (as in “terabit router” or “terabit speeds”)
      pbps (petabits/sec) means quadrillions of bits per second.

      I recognize this is “jargony.” Faster speeds usually mean less waiting around for larger bandwidth applications to run. You won’t care as much about speed if all you do is e-mail and basic web browsing. You will care very much about speed if you need to download large files, watch online video, backup files online, or visit a lot of media-rich websites with sound and video. Many online game enthusiasts demand high speeds to make their game experience better.

      Way back when these broadband networks were planned, engineers figured people would always consume, or download, much more than they would contribute, or upload. Thus, networks were designed to concentrate on higher speed downloads and a considerably slower upload, because they assumed most people wouldn’t need it to be faster.

      Of course, the use of the Internet has changed since the 1990s. Upload speed is becoming more important, especially for online publishing, photographs, peer to peer (torrent, etc.) applications, and home movie sharing.

      Some networks are more vulnerable than others to slowdowns when upload channels get congested.

      Many state of the art fiber networks are easily capable of delivering the same upload and download speeds. At the moment, marketing often has more to do with why you don’t often see those offered. Some companies assume they can leverage additional profit by increasing the price for synchronous broadband plans, and figure they will work on offering those down the road as demand increases.

      • KP says:

        I appreciate that explanation. Many thanks. Does this mean that if I wanted to e-mail attachments like photos, or to submit pictures to a site like Kodak Gallery or Picasa, it would be much slower on Frontier’s DSL than on TW? TW is slow enough as it is. Sorry if this appears to be a digression but I want to be able to talk intelligently when I contact people about my internet service, whether it be providers or legislators.

        • Actually, if you have Standard Road Runner service here in Rochester, it will probably be slower on Road Runner, which only offers 384kbps for uploads. Those with “Turbo” for an additional $9.95 a month enjoy 1Mbps upload speed, which I personally think is too slow (many other cities have 2Mbps upload speed for Road Runner).

          DSL is highly variable from Frontier. It depends on how far away you are from the phone company equipment in their office. Their nominal upload speed is 512kbps, but your results will vary.

          Time Warner will be promoting the fact they now have “boosted” speeds for regular standard service customers with the Powerboost gimmick. It provides a very short burst of faster speed for a few seconds at the outset of the download (doesn’t work for uploads). The faster speed is not sustained (it lasts 3-5 seconds a lot of the time), however, so it only has moderate benefits for subscribers.

      • preventCAPS says:

        Excellent description Phil. I think it would be anice addition to STC to have a dictionary, or introduction to broadband terms or get educated section. One thing I would add is that there are 8 bits in a byte. I would also point out that CAPS are traditionally measued in a form of BYTES and speeds in BITS making it even more complicated for consumers. Then there is the power of 2 issue. Is 1k 1,000 or 1,024 units?

        • Tim says:

          When talking about memory and addressing that memory, a cpu for instance, then the 1024 unit is used or powers of 2. 32 bit CPU’s for instance, are able to address up to 2^32 power of memory or 4,294,967,296 bytes but we humans just say 4GB of RAM instead just to be simple. But if you run a memory test on 4GB of RAM, it will test the amount 4,294,967,296.

          • preventCAPS says:

            I know the difference – what I am really asking is, are the caps in miltiples of 10 (like hard drives are advertised) or powers of 2? And how do you explain it to less knowledgeable consumers? is 40GB cap 40,000,000,000 bytes or is it 42,949,672,960 bytes? That’s a difference of 2,949,672,960 bytes, or roughly 8%

            • Smith6612 says:

              It is 42,949,672,960 bytes for 40 Gigabytes (GB) as data in Bytes is measured in a series of 1024 bytes per Kilobyte. The 1000 rule would apply if you’re talking about Bits, in which case 1,000 bits would equal a kilobit, in which case 40,000,000,000 bits would indicate 40 Gigabits (40Gb). Also, since there are 8 bits to a byte, 1000 bits would equal 125 bytes. This becomes more complex as you begin moving from Binary to decimal, where with bytes, Binary would be the number 1024, where as Decimal would be 1000, but bits remains the same 1000. In computing these days, we often refer to the size of things in Binary, as that is how data is stored often times.

              It’s as simple as learning the metric system, where it’s all based upon a single basic number so to speak.

              As per 32bit vs 64-bit, it’s as simple as taking 2 to the power of whatever you’re looking for, taking the bits and converting it to bytes using the bit to bytes, and then finding the amount of Megabytes, Gigabytes, Terabytes, higher? that the computer can take, in this case with RAM.

            • Tim says:

              Back in the day, even the HDD’s, were measured in powers of 2. Now they are in powers of 10 and say so in fine print. Yes, people can get confused with bits and bytes. Luckily, they haven’t thrown in a nybble or nibble, whatever you prefer, to even inspire more confusion. :-) But you have a valid point in that which system will they use, the power of 10 or 2? Most likely, they will go with the lower figure to suit their purposes, ie power of 10. Want to throw your ISP for a loop? Call up one of their tech support guys and ask that question. I am sure it would be probably funny. Most tech support people are minimally trained.

              • preventCAPS says:

                Back in the day I thought I’d never fill up my brand new 40MB hard disk (that was measured in powers of 2).

                Needless to say, I hope that we don’t need to explain this to consumers as they will only need to understand one word, “unlimited” meaning limitless or without bounds; unrestricted.

                • Tim says:

                  I say we confuse them even more. Let’s see, 2 bytes=1 word, 2 words=1 double word, 2 double words=1 quad word… :-D jk

  4. [...] connectivity…. including wanting it FREE. It’s your voice so say what you want. From: Stop the Cap! Blog Archive Help the FCC Craft A Realistic Broadband Policy The Federal Communications Commission is accepting comments from citizens until July 8, 2009 as [...]

  5. Michael Chaney says:

    Here in Austin we have formed the Austin Broadband Interest Group, a collection of concerned citizens such as myself and small business owners. We’ve submitted our comments to the FCC, and I highly encourage other communities to organize and do the same. A few more comments like this and we could have a major impact on FCC policy.

    http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6520220275

    UPDATE: The actual close of the request for input period was June 8th….not July 8th, but there will be another chance during the request for comment period







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