Editor's Note: Why am I not surprised that the industry wants the definition of broadband limited to the minimum? I live in Brooklyn, and what passes for cable-modem "broadband" is abysmal already. Why let the industry define-down expectations to what they are willing to provide before added fees?

fcc( - In response to the Federal Communications Commission's request last month for comments about a definition of the term "broadband," key industry players have advised the FCC to tread carefully. The National Cable and Telecommunications Association, for example, is cautioning against incorporating substantive requirements regarding speed, price or openness.

"The commission should not use the process of defining 'broadband' as a vehicle for imposing substantive obligations on providers of broadband services," said NCTA General Counsel Neal Goldberg. "Rather, as Congress did in defining terms like 'cable service,' 'telecommunications service,' and 'information service,' the commission should adopt a more generic definition that focuses on the core functionality."

Metrics and Measurements 

Congress has defined broadband as any technology with the capacity to transmit data to enable a subscriber to originate and receive high-quality voice, data, graphics and video. The FCC wants to redefine the term with a higher degree of precision in order to complete its recommendations to Congress on the implementation of a national broadband plan, said Carlos Kirjner, a senior FCC adviser.

"If we want to decide who has and who does not have broadband, we actually need to agree on what we mean by broadband," Kirjner said.

The FCC has noted that the advertised throughput rates of service providers generally differ from actual rates, are not uniformly measured, and place different constraints over different technologies. The FCC hopes to specify the general form, characteristics and performance that broadband should include.

"To ensure that consumers have a clear and accurate view of what they are getting for their money, we need to decide what the important metrics are and how to measure them," Kirjner said.

However, the NCTA and Comcast disagree, saying there is no effective way to control all these factors in every instance.

"The 'provisioned' speed is still the most useful metric in evaluating whether any particular Internet service is 'broadband,'" Comcast's legal team said. "In addition, using 'provisioned' speed will allow the commission to leverage existing data-collection capabilities, across time and across agencies, without incurring substantial new administrative burdens."

A Question of Speed 

Verizon and the NCTA want the FCC to continue to use the simple definition for broadband that the commission established last year: Services with download speeds of more than 768 kbps and upload speeds of more than 200 kbps.

"Attempting to incorporate all of the potential considerations of a broadband customer into the definition of 'broadband' is unnecessary and could prove counterproductive," Goldberg said. "The better approach is for the commission to define broadband in a simple, straightforward manner and establish a set of goals and metrics that build on this definitional framework."

However, Free Press considers download speeds of 768 kbps and upload speeds of 200 kbps to be clearly unacceptable in light of the range of media-rich Internet applications available today. At a minimum, the media watchdog said, broadband should be defined as a symmetrical telecom service that can reasonably deliver "five megabits per second (Mbps) of bandwidth in both the down and upstream directions, at latencies low enough to enable high-quality real-time voice and video two-way communications."

"This bare-minimum threshold standard should apply irrespective of technology, and should serve as a baseline for both mobile and fixed services," Free Press Research Director Derik Turner advised.

The CTIA wireless association and Verizon, however, want different definitions to apply to fixed and wireless broadband systems. "Separate targets for fixed and mobile services are needed in light of the technological differences that affect the performance constraints and present other unique challenges for mobile providers," Verizon's legal team said.