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

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.