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


My $0.02.

The IEEE Wireless Dictionary defines broadband as:

broadband: A communication system that has a broad, i.e., large, data
bandwidth. Broadband is an imprecise term normally used to differentiate
systems that provide voice quality (10’s of kb/s) with those that are
fast enough to provide video services (5–20 Mb/s).

(but then I am biased as I am the author and wrote that bit).

Having said that, it appears that the FCC is asking the correct
questions.  Here are answers:

a-z: The FCC shall exclude itself from any definition of broadband or
its usefulness as it is a government agency and is, by definition,
incapable of useful input in the marketplace.  The FCC should only apply
such regulations as those that allow maximum use of the limited
allocations without prejudice to the providing entity, ensuring maximum
choice of the consumer.

Translation: The FCC should be there to ensure the free market, the free
citizens will decide its best use.

James Gilb

Paul Nikolich wrote:
> Mike,
> 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.
> Regards,
> --Paul
> 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 indicators;
> 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
> indicators.
> 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
> levels;
> 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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