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[802SEC] FW: [STDS-802-16] Fwd: 802.18 Conference Call - 26 August - 2:00 p.m. CDT - FCC Request for Help to Define "Broadband"

Dear EC and RR-TAG,

Please find attached and below some thoughts on this topic from Rex. 

As I receive inputs, formal or otherwise, I will forward them to both reflectors.



-----Original Message-----
From: Rex Buddenberg [] 
Sent: Monday, August 24, 2009 11:03
To: Mike Lynch
Cc: Roger B. Marks
Subject: Re: [STDS-802-16] Fwd: 802.18 Conference Call - 26 August - 2:00 p.m. CDT - FCC Request for Help to Define "Broadband"


(And Roger; thanks for forwarding).

FCC is, IMHO, asking exactly the right question.  And we should recall that it asked the same question in para 15 of the NOI ... the very first question after the front matter.

I've reattached my personal comment to the NOI and below is the offending specific clip:

(15). “Broadband can be defined in myriad ways.” Recommend you go behind the definition to intent.  The stated requirement should be to 'extend the internet'. In the case of emergency services, this means 'extend the internet to mobile platforms' such as fire trucks, ambulances and police cars. Also in the case of emergency services, we should fix the intent as 'extend the internet to reach to the citizenry served', whether they are mobile (e.g. in automobiles) or not (at home, or work, or school).
        The meta observation here is that regardless of the definition of 'broadband' all candidate technologies are packet switched ones – they can be used to extend the internet. By contrast, those technologies that are generally classed outside of the foggy definition of broadband are circuit-switched ones. Recommend that you consider replacing 'broadband' with 'packet switched' or 'routable network segment' – terms that clearly connote extending the internet.

You're welcome to use, fold, spindle, mutilate ... as you see fit.

Primary.  Extend the internet should be the principal criteria.
Routable network.  

	As opposed to 'access the internet' which drops you into the dial-in-modem-over-PSTN mentality.  The telco marketing folks used 'always on' as an attribute attempting to sell DSL. 

I notice that the DA 09-1842 notice does not use the terms 'internet'
nor 'routable network'.  09-51 uses the term 'internet' but not 'routable network'.

IEEE 802 has a proper leg up on this: any technology that uses the 802.2 LLC at the top of layer 2 qualifies.  

IMHO, single definition.  At this stage we need not make the definition distinguish between wired and radio.  

This approach addresses 1.a and 1.b of DA 09-1842.  And it makes the rest of para 1 clearly secondary issues (that properly fall outside the single definition).  

Secondary.  Stability of the MAC is a secondary concern.  1.d and 1.f.

Also rans.  All the other parts of para 1 are of concern in a specific
design, but should be outside the definition.   Capacity is a convenient
term, but is really a side effect.  And it can be used as a bludgeon to circumvent the intent.  Aaah, I'll build a 1M link rather than a 1k one.
But if it's a 1M point-to-point link, then we don't get extend the internet.  (this argument applies to radio-WANs but not to terrestrial

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Attachment: broadband_plan_budden_comment.pdf
Description: Adobe PDF document