Showing posts with label NOI. Show all posts
Showing posts with label NOI. Show all posts

Wednesday, June 3, 2009

FCC National Broadband Plan: Defining Access

It's a busy time of year with my daughter graduating from high school, the end of the semester, etc, etc, etc. Things are settling down now and I wanted to get back to the Federal Communications Commission (FCC) Notice of Inquiry (NOI) to develop a modern national broadband plan that will seek to ensure that every American has access to broadband capability.

As I've written in the past, the NOI is currently open for comment until June 8 with FCC reply to comments on July 7. In my last post I took a look at Defining Broadband Capability. Today let's look at Defining Access to Broadband as described in the 59 page report. I've listed selected items the FCC is seeking comment on, followed by my comments.

The FCC seeks comment on what it means to have access to broadband capability. For instance, the FCC seeks comment on whether the determination of availability should take into consideration the provision of broadband at locations, such as at home, at work, in schools, in transit, in libraries and other similar community centers, and at public Wi-Fi hotspots.

Broadband capability needs to be everywhere. Prioritizing (for example, saying a library requires more bandwidth per user than a home) makes little sense. We need to make broadband available to everyone.

The FCC seeks comment on whether to interpret the capability term differently
depending on the technology used or whether it is used in a fixed, nomadic, or mobile context.

A minimum definition should be set that all technologies should meet and then categories should be broken out. For example, a fiber to the home (FTTH) fixed technology connection is going to have considerably more capability than a mobile wireless connection.

The FCC seeks comment on whether (and if so, how) the Commission should evaluate the term “access”
with certain basic consumer expectations in mind.

In 2005 the Commission adopted an Internet Policy Statement in which it committed “to preserve and promote the vibrant and open character of the Internet as the telecommunications marketplace enters the broadband age” by incorporating four consumer-based principles into its ongoing policy making activities. (1) “consumers are entitled to access the lawful Internet content of their choice”; (2) “consumers are entitled to run applications and use services of their choice, subject to the needs of law enforcement”; (3) “consumers are entitled to connect their choice of legal devices that do not harm the network”; and (4) “consumers are entitled to competition among network providers, application and service providers, and content providers.”

I believe these 4 principles are critical as we move forward and these principles should be turned into rules (through a rulemaking).

To what extent should the Commission consider price or marketplace competition for broadband as it considers whether people have access to broadband capability?

Competition is key if we want bandwidths from different providers to leapfrog and prices to drop. In Massachusetts we've seen fierce competition in the eastern part of the state as Verizon (FiOS) and the cable companies go back and forth with each other. In Western Massachusetts (where I live) FiOS is not available and we are seeing little competition when compared.

Areas where there is only a single provider typically have to wait for long periods of time to see new broadband delivery technologies. More competition in under-served areas is critical areas or these areas will continue to fall further behind. I'd like to see the national broadband plan focus stimulus money on these areas with limited competition and capability.

What benefits to consumers are unique to differentbroadband technologies? How should the Commission consider the different qualitative features discussed in the definition of broadband, such as latency, peak download speed, and mobility?

We must set these features aggressively and at a level that does not just compete but leads the rest of the world - this must be our goal. The OECD maintains a portal that provides access to a range of broadband-related statistics gathered by the OECD. The OECD has indentified five main categories which are important for assessing broadband markets - Penetration, Usage, Coverage, Prices, and Service & Speeds. For example, fiber is the dominant connection technology in Korea and Japan and now accounts for 48% of all Japanese broadband subscriptions and 43% in Korea. With fiber comes lower latency, higher peak download speeds and (yes) even more mobility.

The FCC also seeks comment on the extent to which access hinges on affordability.

Simply put, it needs to be fast and it needs to be cheap. Referring to the OECD portal again and as an example, on average, subscribers in OECD countries pay 15 times more per advertised megabit of connectivity than Koreans. We must be faster and cheaper than Korea if we want to compete with the rest of the world.

The FCC seeks comment on what it means for a person with disabilities to "have access" to broadband capabilities.

The report references the Assistive Technologies Act of 2004, supporting state efforts to improve provision of assistive technology to individuals with disabilities; the Americans with Disabilities Act of 1990,requiring common carriers to provide telecommunications relay services for deaf and speech-impaired individuals; and the Amendment of the Commission’s Rules Governing Hearing Aid-Compatible Mobile Handsets; Petition of American National Standards Institute Accredited Standards Committee C63, that focuses on adopting hearing aid compatibility requirements for mobile wireless devices.

Higher bandwidths and lower costs per megabit will drive innovation and applications that help and support people with disabilities. That said, assistive technologies must continue to be regulated and ratcheted up as bandwidth and access continues to improve.

I believe residential broadband (to the home) is key in our country. Homes in our broadband equation are the lowest common denominator. Lots of inexpensive and reliable bandwidth to everyone's home will drive bandwidth up and costdown at work, libraries, public Wi-Fi hotspots, etc. We must set our residential broadband bar higher than the rest of the world in each of the five OECD portal categories.

Wednesday, May 20, 2009

FCC National Broadband Plan: Defining Broadband Capability

I've been writing about the Federal Communications Commission (FCC) Notice of Inquiry (NOI) to develop a modern national broadband plan that will seek to ensure that every American has access to broadband capability. The NOI is currently open for comment until June 8 with FCC reply to comments on July 7.

The 59 page report starts with some introductory information that I've covered here in prior posts. The FCC hopes to establish these four primary goals and benchmarks:

  1. Defining Broadband Capability
  2. Defining Access to Broadband
  3. Measuring Progress
  4. Role of Market Analysis
Today, let's take a look at Defining Broadband Capability.

Broadband is defined lots of different ways and the FCC is seeking comment on how the definition should capture the various issues that should be considered as the FCC defines broadband capability, including how to take into account the various existing and emerging technologies.

According to the NOI, the FCC currently uses the terms advanced telecommunications capability, broadband, and high-speed Internet. Most of us think of broadband as data - high speed data but just data. That's changing for many of us - we're in the middle of the migration to all IP networks and I believe voice and video must be included along with data in the new broadband definition. I'd be fine with just calling it just broadband.

We're also dealing with a wide range of technologies - Fiber To The Home (FTTH), Fiber To The Node (FTTN), WiMAX, LTE, DOCSIS, ADSL, etc. Each of these provides a different range of bandwidths depending on distance, signal strength, etc. I'd like to see specific bandwidth ranges that can be easily adjusted as we ramp up speeds. This is the way we did it with dial-up data access using analog modems - 300 bps became 1200 bps became 2400 bps, etc. I also believe we need to define both upstream and downstream bandwidths for these ranges. Here's the way the FCC started defining bandwidth tiers of service last year:

First Generation data: 200 Kbps up to 768 Kbps
Basic Broadband : 768 Kbps to 1.5 Mbps
1.5 Mbps to 3.0 Mbps
3.0 Mbps to 6.0 Mbps
6.0 Mbps and above

A service is categorized if bandwidth in only one direction (the faster direction) meets the ranges listed. Most consumer services are asymmetrical with more bandwidth provided in the downstream direction that the upstream direction. I'd like to see these tiers broken out further and include separate listings for upstream and downstream bandwidths.

I'd also like to see average speeds calculated over the course of 24 hour/7 day a week periods be listed. It makes no sense for my provider to list maximum speeds that I can only get at 3 in the morning when all of my neighbors are sleeping.

In addition, these tier levels must be dynamic and adjust up with technology improvements. I hope I'm not still sitting at the 3-6 Mbps tier (in one direction) a year from now.

I don't believe there should be different definitions or standards for the type of broadband service provided. For example, we don't need separate definitions for mobile broadband services (e.g. wireless) and fixed broadband services (e.g. cable modem). Bandwidth is bandwidth so keep them all the same.

I also don't believe rural and other hard to get to areas should have lower tier standards and definitions. We must make every effort to provide equal service to as many people as possible in our country.

For details be sure to see the entire 59 page report. In the next post I'll discuss Defining Access to Broadband.

Wednesday, May 6, 2009

FCC National Broadband Plan: The Development Approach

I've been writing about the Federal Communications Commission (FCC) Notice of Inquiry (NOI) to develop a modern national broadband plan that will seek to ensure that every American has access to broadband capability. The NOI is currently open for comment until June 8 with FCC reply to comments on July 7.

The 59 page report starts with an introduction and some background I've summarized in prior posts. Today I wanted to begin taking a look at the Discussion section of the report - what most consider to be the "meat". The section begins with covering the approach the FCC is taking to develop the plan and asks how the Commission can identify and promote the best and most efficient means of achieving this congressional mandate.

Here's a list of the important questions the FCC is seeking comment on:

How should broadband capability be defined going forward, and what does it mean to have access to it?

How can the FCC provide “an analysis of the most effective and efficient mechanisms for ensuring broadband access by all people of the United States.”

How
can the FCC develop “a detailed strategy for achieving affordability of such service and maximum utilization of broadband infrastructure and service by the public.”

How can the FCC evaluate “the status of deployment of broadband service, including progress of projects supported by the grants made pursuant to this section.”

How
can the FCC develop “a plan for use of broadband infrastructure and services in advancing” a variety of policy goals.

How
can the FCC evaluate the development of a national broadband plan in light of a variety of other related statutory directives and whether additional elements should be included in the national broadband plan.

Finally, because this plan will not be solely the FCC’s to implement, the FCC seeks comment on how the Commission, in both the development and implementation of a national broadband plan, should work collaboratively with other agencies at all levels of government, with consumers, with the private sector, and with other organizations.

How will it be done? The FCC hopes to answer these questions by establishing four primary goals and benchmarks:
  1. Defining Broadband Capability
  2. Defining Access to Broadband
  3. Measuring Progress
  4. Role of Market Analysis
In future posts I'll take a look at each of these primary goals and will comment.

Friday, May 1, 2009

FCC National Broadband Plan Notice Of Inquiry Process




Last week i wrote about the Federal Communications Commission (FCC) Notice of Inquiry (NOI) to develop a modern national broadband plan that will seek to ensure that every American has access to broadband capability. The plan creation has been charged by Congress as part of the American Recovery and Reinvestment Act of 2009.

The 59 page NOI broadband plan document is open for comment until June 8, 2009 with the FCC required to reply to comments on July 7, 2009. Let's look at the process.

Notices of Inquiry (NOIs) are Issued by the FCC as a way to collect comment, ideas and input on given topics. NOIs are given time deadlines and any interested party can submit comments before the dates indicated on the first page of the NOI. Comments can be filed a couple different ways:
  • Paper filing that requires four copies of each filing be addressed and delivered to the Commissions Secretary.
Details on filing procedures can be found starting on page 41 of the NOI.

What can be commented on? Here's a quote in the NOI appendix from FCC Commissioner Robert M. Dowell:

Because we begin with a clean slate, this Notice of Inquiry presents myriad questions. Some are narrow and specific. Others are broader. All are important. If commenters think of questions we should have asked but did not, please raise them. If you disagree with the premise of a question, by all means say so. Your advice will help us to develop a thoughtful, reasonable, practical and pragmatic plan.

Critical work as we move forward in our country.