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

EC and RR-TAG:

I have a conflicting BOG call at the time so probably won't be able to participate.  I do not believe a single definition will work.  Similarly, it can't be defined in terms of link speed, as the advertised link speed is not usable bandwidth, bandwidth can be throttled at aggregation points, etc.  

When talking about speeds for residential broadband access, the link speed is only one of the criteria and typically not the most restrictive, including the link rate of my "broadband" modem.  It is not uncommon for an ISP to put explicit rate limiters on my data that may be less than the effective link rate of the slowest link in my path.  Independent of technology, because of aggregation, any definition has to incorporate probability as has been the case for POTS service for throughout my lifetime.

If I can only get the bandwidth my application requires at 3:00 in the morning, I wouldn't consider the service broadband no matter how big the bandwidth measurement at the limited time.

FYI, Scott Bradner wrote some rather negative things about the FCC's history on this topic in a recent Network World (


-----Original Message-----
From: ***** IEEE 802 Executive Committee List ***** [] On Behalf Of Paul Nikolich
Sent: Wednesday, August 26, 2009 11:07 AM
Subject: [802SEC] 802.18 Conference Call - 26 August - 2:00 p.m. CDT - FCC Request for Help to Define "Broadband"


May I suggest the agenda item (3) be focussed on answering the specific FCC 
questions in the Public Notice--which I've cut-and-paste below.



We now seek more targeted comment on three aspects of this issue: (1) the 
general form, characteristics, and performance indicators that should be 
included in a definition of broadband; (2) the thresholds that should be 
assigned to these performance indicators today; and (3) how the definition 
should be reevaluated over time.

1. Form, Characteristics, and Performance Indicators. Much of the discussion 
of any proposal to define "broadband" tends to center on download and upload 
throughput.9 Download and upload throughput are important, but neither is 
precise or diverse enough to describe broadband satisfactorily.10 For 
example, advertised throughput rates generally differ from actual rates, are 
not uniformly measured, and have different constraints over different 
technologies.11 In addition, it is unclear what the end points of the 
connection are over which throughput is measured or whether the performance 
of the end points is reflected in the stated throughput. Moreover, there are 
network characteristics - such as latency, reliability, and mobility - that 
are relevant for certain applications but not others. Accordingly, we seek 
comment on:

a. the form that a definition of broadband should take;
b. whether to develop a single definition, or multiple definitions;
c. whether an application-based approach to defining broadband would work, 
and how such an approach could be expressed in terms of performance 
d. the key characteristics and specific performance indicators that should 
be used to define broadband;
e. what segment(s) of the network each performance indicator should measure, 
such as the local access link to the end user, or an end-to-end path;
f. how factors such as latency, jitter, traffic loading, diurnal patterns, 
reliability, and mobility should specifically be taken into account;
g. whether different performance indicators or definitions should be 
developed based on technological or other distinctions, such as mobility or 
the provision of the service over a wired or wireless network;
h. the feasibility and verifiability of measuring different performance 

2. Thresholds. After identifying key characteristics and performance 
indicators, a definition of broadband must identify acceptable thresholds - 
typically minimums. Accordingly, we seek comment on:
a. what minimum thresholds should be assigned to the performance indicators;
b. the minimum thresholds necessary for broad classes of applications to 
function properly;
c. whether we should adopt multiple, escalating tiers of minimum thresholds.

3. Updates. The Internet and broadband networks have been characterized by 
rapid evolution and change. While a static set of objectively measured 
thresholds may be useful to compare networks at a given time, or over time, 
a static definition will fail to address changing needs and habits. 
Accordingly, we seek comment on:
a. what ongoing process should be put in place to update the definition, 
particularly the threshold
b. how often should such updates should occur;
c. what criteria should be used to adjust thresholds over time;
d. how modifications over time to the definition will affect the Commission's 
ability to collect and
publish meaningful data on broadband deployment and adoption.

----- Original Message ----- 
From: "Mike Lynch" <freqmgr@SBCGLOBAL.NET>
Sent: Wednesday, August 26, 2009 11:33 AM
Subject: Re: [802SEC] [802-18] [802SEC] 802.18 Conference Call - 26 August - 
2:00 p.m. CDT - FCC Request for Help to Define "Broadband"

> Dear EC and RR-TAG,
> A friendly reminder of today's call - as if you haven't been loaded up 
> with
> other emails on this topic!
> At the beginning of the call please email myself and Peter Murray stating
> your presence on the call and your affiliation. This will augment but not
> replace the normal roll call.
> Our agenda is:
> 1) Roll call
> 2) Patent policy:
> 3) Review of inputs and general discussion. Please note that I will keep
> sending inputs/comments to both reflectors right up to the start of the
> meeting.
> 4) Any other business.
> The is to develop an acceptable definition of "broadband" that can be
> submitted to the FCC by next Monday's deadline. I propose that we focus on
> the definition and that I will provide the boilerplate to introduce the
> document. The full document will be submitted for an EC review prior to
> filing with the FCC by CoB Monday. Presuming we only have a 5 day EC 
> review
> this filing will be from 802.18. I am not certain that there is time to 
> have
> an EC ballot so that it can be from 802.
> Regards,
> Mike
> +1.972.814.4901 

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This email is sent from the 802 Executive Committee email reflector.  This list is maintained by Listserv.