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[802SEC] FW: found this, think it is interesting on the define Broadband questions filed improperly

From Nancy and it relates to our call later today.






From: Nancy Bravin [] 
Sent: Tuesday, August 25, 2009 19:58
To: 'Mike Lynch'
Subject: found this, think it is interesting on the define Broadband
questions filed improperly


Reply Comments

D. Maples / 20 July 2009

Thank you for the opportunity to comment on the Federal Communications

Commission's Notice of Inquiry (NOI) 09-31. Because this NOI is so
voluminous and

asks so many questions, I have responded only in areas where I believe I may

some value. My comments are linked to the numbered paragraphs in your NOI.

Commission's questions are restated in italics.

16. .the Commission currently uses the terms "advanced telecommunications

capability,""broadband," and "high-speed Internet." Should these definitions
be unified, or

shouldthey have separate meanings for different purposes, keeping in mind
that current and

future broadband platforms will increasingly support "high-speed Internet"
as one of several

offered services including voice, video, private data applications, and the

The Commission (and ideally the rest of the Federal government as well)
should define

and use a single term ("broadband access") for this purpose. The terms

telecommunications capability" and "high-speed Internet" should be deleted
if they

overlap this definition. The term "broadband access" should be defined as
access to

digital communications transport that does not travel through the legacy
public switched

telephone network. The capability should be specified in terms of average

bits per second, with a maximum latency, and a probability of delivery of no
less than

99%. The average should be a worst-case average calculated over all delivery

conditions, and preferably over a large number of packets or frames (e.g.
1,000 or

more). The measurement should exclude any header or other non-payload

In addition, to the extent that broadband is defined by "speed," should the

consider raising the speeds that define broadband?

The Commission should establish and maintain minimum average delivered

figures in both uplink and downlink directions, with an initial minimum of
no less

than 2 megabits / second. While by most measures this is very slow, it is
still a step up

from the current definitions. This figure should represent the absolute

delivered to an end user. It would be desirable for the FCC to set goals
based on

technology that are higher than this minimum. The Commission should further

a defined maximum figure for latency. Finally, the Commission should
future-proof this

definition by establishing an algorithm that adjusts this minimum level
based on the

rollout of new technology.

Should we distinguish among the various broadband technologies?

In rating what is and is not a "broadband access" service, the Commission
should define

both "wired" access (in which the end user is served by some physical
connection, be it

fiber, twisted-pair metallic, or coaxial metallic cables) and non-wired
access (in which

the end users is served by either a radio-frequency (RF) or free-space
optical link) and

distinguish between them. Non-wired access will almost always be slower in

than wired access. 

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