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Re: [802SEC] 802.18 Conference Call - 26 August - 2:00 p.m. CDT - FCC Request for Help to Define "Broadband"


I won't be able to join you on your August 26th call (besides, it looks like I would not be allowed a vote by your announced rules) and to provide the sort of answer that is needed for legislative purposes will be tricky and challenging. I would like to add a though to the process since I have been involved with broadband networking (to my belief) longer (since 1973)than anyone else in 802.

To this end, I will requote my often said statement about Ethernet.
This aspect is not widely acknowledged or realized and runs strongly counter to the legacy carrier line of (legacy) reasoning that bandwidth is expensive.

"The job of Ethernet is to not be the slowest element in the (end-to-end) system."

i.e. to be at least fast enough that the bandwidth of something else (often operating system and display rendering bandwidth) is the thing that actually determines the speed of the application as seen by the user. Thus it has (most definitely) been a moving target over the last 25 years.

In the context of the government defining "broadband" as a national deployment goal, the goal should be the same (and there will be massive pushback because of legitimate cost issues). That is, the goal is to get the bandwidth of the network out of the way of the long reach applications of the present and future that are screaming to be made available to the American public at large.

I hope this will be helpful.
I'm eager to see your output.

Best regards,

P.S. The term "broadband" should be orthogonal to the issue of "network neutrality" but probably will not be in the requested context. Therefore your response probably should mention that term too.

On 8/21/09 2:32 PM, Mike Lynch wrote:
Dear EC and RR-TAG,

Paul kindly brought to my attention that yesterday the FCC released an item
that asks for help in defining "broadband". This relates to the FCC's
development of a National Broadband Plan (NBP).

The following link will take you to the item:

As you will see the comment due date is 31 August and reply comments are due
8 September. Not only is this a very short notice proceeding but it falls
between IEEE 802 meetings. Paul has asked that we try to implement "Option
1"  contained in my earlier email to the EC and develop a response to be
filed on 31 August.

There is a reference to a previous FCC NOI regarding a nationwide broadband
network, GN Docket 09-51. At the May interim 802.18 made comments on that
NOI. The earlier FCC NOI is available on 802.18's Mentor web site:

The 802.18 comments are available at:
nt=6520220911>  &id_document=6520220911

To do this we can take advantage of 802.18's ability to meet and approve
documents on conference calls. What I propose is that all those WGs in 802
(not only the wireless groups) meet by conference call at the date and time
given below. I further propose that each interested WG, as much as possible
in the limited time available prior to the call, develop views for
discussion on what is meant by "broadband". In order to make the call work
more smoothly I ask that each interested WG chair (or designated
representative), with no more than 2 "advisors", participate in the call.
All wireless chairs already have voting privileges in 802.18 and for this
call that privilege will be extended to all other WG chairs.

Date - 26 August 2009

Time - 2:00 pm/14:00 CDT

Bridge number - TBA NLT Tuesday, 25 August

Pass code - TBA NLT Tuesday, 25 August

Presuming success on the call the document will be submitted on 27 August
for EC 5 day review and approval.

Again let me say that I realize that this is a very short notice for a
meeting to deal with a topic such as this one. It is important that we try
and put the IEEE 802 view before the FCC on time. Beside the normal
boilerplate at the beginning of the comments we will also comment to the FCC
about the very short timeframe - 11 days from the public notice of the
request to the comment date.

If possible please circulate any proposed text prior to the call.

Glad to discuss.



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