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[802SEC] FW: [802-18] 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,

Another input related to our call tomorrow.



-----Original Message-----
From: [] On Behalf Of Dan
Sent: Tuesday, August 25, 2009 10:24
To: Mike Lynch
Subject: Re: [802-18] FW: [STDS-802-16] Fwd: 802.18 Conference Call - 26
August - 2:00 p.m. CDT - FCC Request for Help to Define "Broadband"

Mike.. Here is a IEEE-USA CCP's contribution to the BB NOI which
you/the group might also want to consider.

I hope to be joining the call tomorrow about 20 minutes after it starts..


Dan Lubar

On Mon, Aug 24, 2009 at 1:04 PM, Mike Lynch<> wrote:
> 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
> Regards,
> Mike
> -----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"
> Mike,
> (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
> 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
> 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
> WANs)

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