[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.
Regards,
Mike
From: Nancy Bravin [mailto:nbravin@earthlink.net]
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.
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