I want full disclosure of what I receive for my subscription dollars, not adverting hype.

The FCC is reconsidering the definition of broadband. This will affect the broadband provisions of the American Recovery and Reinvestment Act (ARRA) of 2009. It could also affect what is provided to broadband ISP subscribers.The FCC issued a Public Notice, "Comment Procedures Established Regarding the Commission's Consultative Role in the Broadband Provisions of the Recovery Act," GN Docket 09-40, DA 09-668, released March 24, 2009. There have been previous notices in 2007 and 2008 with comments from industry and consumer groups.

One of the industry groups is the Telecommunications Industry Association (TIA). The TIA's comments can be found here (PDF). This filing is a successor to a previous filing by the TIA in 2007. The TIA submission states:

As part of its National Broadband Plan, the Commission has stated that it must incorporate the use of broadband infrastructure and service in advancing a broad array of public interest goals, including consumer welfare, civic participation, public safety and homeland security, community development, health care delivery, energy independence and efficiency, education, worker training, private sector investment, entrepreneurial activity, job creation and economic growth, and other national purposes (see TIA comments, Broadband Industry Practices, WC Docket No. 07-52 at 9, June 13, 2007). These public interest goals are achievable with the added element of broadband.

The FCC notice seeks comments on:

1. The characteristics, form and performance indicators that should be part of the broadband definition

2. The thresholds assigned to the performance indicators

3. Since the definition of broadband appears to change, the FCC wants to know how that definition should be reevaluated over time as future technologies develop

The TIA comments covered many aspects, several of which I had not considered. The TIA recommends "as it has in previous filings, that the Commission not limit itself to one narrow and arbitrary definition of broadband."

The definition of broadband will affect the cost of service. It will also stimulate or retard the growth of Unified Communications applications. It could leave out some mobile services and only affect wireline services. It could improve the chances that net neutrality will continue or be lost forever.

Did you know that previous broadband definitions did not include two way transmission capabilities? Section 706(c) (1) includes all the right words about the types of traffic to be carried and refers to the capability that enables users to "originate and receive" information. The TIA says this implies two way transmissions but it does not define that the transmission be symmetric. The TIA reasserts that the broadband definition include two way transmissions.

A second major point is that the TIA wants wireless technologies included in the definition, especially the minimum speed. The TIA notes that wireless technologies are slower than wireline technologies and should be separately addressed in the definition. The inclusion of both wireline and mobile technologies is paramount in the broadband definition.

When you consider how broadband service is described, the definition will broaden or restrict the application of the federal stimulus package, who gets how much for doing what. The broadband definition can also help the subscriber to understand the limitations offered in the broadband access services.

I find this later point to be significant. In previous blogs, I wrote of the Comcast and AT&T behavior towards ISP subscribers, how Comcast cancelled bandwidth hogs and AT&T wants to censor content. See "More Data on Comcast and Cox Traffic Blocking," "Metering the Internet," and "Comcast, the Internet and Restrictions."

Here are some suggestions to add to the broadband definition:

* Fully define the delivered, not advertised speed in both directions, provided to the individual subscriber

* Define peak bandwidth for the individual subscriber, not a network average

* If 768kbps is to be the minimum speed for broadband, then most DSL subscribers will not be covered in the definition, which would affect how their ISP service is defined or not defined by the FCC

* If capacity, measured in megabytes, is limited, how is the volume calculated? Is it calculated for each direction or the sum of both directions?

* How is the subscriber be informed of pending over-usage and the grace period allowed for responding to the over-usage

* Define time of day limits if imposed

* Any application limitations should be disclosed before the subscribers signs up

* Easy and no-penalty subscription cancellation policies

* Broadband cross network latency that can be demonstrated in real time to the subscriber, not some overall network average that obscures the reality

* The definition should not value one performance aspect over another such as speed vs. data volume vs. mobility

My suggestions are not to create a uniform description of the performance metrics delivered. I want a uniform description of how the metrics are defined so I can compare the service offerings directly. I want full disclosure of what I receive for my subscription dollars, not adverting hype I cannot depend on and service agreements that are so one sided and vague. If broadband services are part of your organization's plans such as teleworking, you should follow the FCC to evaluate how the new broadband definition will affect your operations.I want full disclosure of what I receive for my subscription dollars, not adverting hype.