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From Nancy and it relates to our call later today. Regards, Mike From: Nancy Bravin [mailto:firstname.lastname@example.org] 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 add some value. My comments are linked to the numbered paragraphs in your NOI. The 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 like?. 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 "advanced 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 delivered 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 information. In addition, to the extent that broadband is defined by "speed," should the Commission consider raising the speeds that define broadband? The Commission should establish and maintain minimum average delivered bits-persecond 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 minimum 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 establish 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 speed than wired access. ---------- This email is sent from the 802 Executive Committee email reflector. This list is maintained by Listserv.