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Originally featured on BroadcastEngineering.com
Sep 28

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9/28/2009 10:00 AM  RssIcon

duck.jpgThe FCC opened a Pandora’s box by asking for public comment on the definition of broadband. The result has been a long list of proposed definitions served up by competitive and self-interested groups all claiming to have the only correct characterization. The problem is there is little commonality between the proposals.

If the players can’t even agree on a common definition of broadband, how can we hope to employ performance measurements of such services? So far, about the only commonality is that they all disagree on how to define it.

Among the most vocal in expressing their viewpoints are the broadband providers. This includes cable companies like Comcast, AT&T along with the NCTA. As is obvious from the definitions these groups have suggested, the last thing they want is for the FCC to define broadband in such a way that delivery performance could be measured.

What each of these companies seems to be trying to do is water down the definition to the point that it becomes pretty much worthless. They appear to be trying to get the FCC to adopt something with characteristics that basically can’t be measured. Bottom line: If broadband parameters can’t be measured, then providers can’t be penalized for not delivering it; however, you define "it." These companies apparently hope their confusing laundry list of pretty much inconsequential technology nuances will sufficiently muddy the water.

After all, if you can’t define it, you can’t measure it. And if you can’t measure it, then you can’t be penalized for not delivering it.

I see broadband as an IP pipe that delivers a certain (measurable) level of electrical performance. Broadband can then easily be defined by the number of bits per second delivered to a user, measured over a specific time. Bits per second doesn’t sound like rocket science to me.

However, the broadband players respond. "No. The real definition is much more problematical. A whole range of other (mostly unmeasurable) factors must be included. It’s not just a simple matter of measuring bits per second," they claim.

The NCTA submits that it is impossible to develop “a single figure that consistently and reliably describes the ‘actual’ speed of all types of broadband connections for all purposes . . . The Commission should continue to look at maximum advertised speed rather than some measure of actual speed.”

Apply NCTA’s self-serving logic to the sale of cars would open all kinds of new advertising opportunities. Local car dealerships could advertise cars as having 500mpg, knowing that this level of performance was possible, but only if you lived at the top of a mountain and only measured gas consumption while coasting downhill with the engine off.

The NCTA’s reasoning is enough to make an engineer’s head spin.

Cable service providers similarly want to cloud any definition of broadband. For instance, Comcast claims that “the actual online experience of any particular consumer at any particular moment in time involves a wide range of factors, many of which are outside the control of the Internet service provider.” The cable company says that instead, the commission should use “the provisioned speed [as] the most useful metric in evaluating whether any particular Internet service is broadband.”

The company’s position is so totally like the bank commercials I’m seeing on TV. A room has two little girls sitting at a table. An adult guy asks one little girl if she wants a pony. When she responds yes, he gives her a little toy pony. He then asks a second little girl if she wants a pony and when she says yes, he delivers a real, live pony.

When the first little girl complains that she wants a real live pony, the guy says she should have read the fine print.

The Comcast position is nothing more than a bait and switch. Unhappy customers will be told they should have read the fine print when they complain that they are not getting the level of service they expected. Cable companies can simply reply, “Well, the signal is leaving here okay, so it’s not our problem.”

By similar Comcast logic, if your TV facility has a 3G router, does that make your signal “3D” compatible? After all, viewers "could" get 3D — someday — through your equipment.

Others suggest that applications be included in any measurement of service performance. They claim having broadband means that you must automatically receive a minimum set of features and functions. If an ISP sells what it calls “broadband service," should the customer be able to simultaneously watch a YouTube video, all while sending e-mail, listening to Internet radio and using FTP to download a BitTorrent file? If even one of these (or other) services doesn’t perform properly at any given user’s location, does that mean the service isn’t really broadband?

The Internet’s big brother, Google, wants any definition of broadband definition to go beyond a specific list of services or features. Google wants it to guarantee “that Americans have access to speeds that enable full utilization of broadband services and applications. . . The FCC should further make clear that there must be a sufficiently robust connection to permit users to receive, generate and interact with voice, data, graphics and video, which will enable users to receive the maximum value of broadband.” While that laundry list pretty much covers everything, at least from the Google perspective, it simultaneously says nothing of value. How do you measure a “robust connection?” At what point do you have robust, and when do you not?

AT&T offers a more limited definition of broadband, saying that it should include a set of applications including e-mail, IM and Web browsing. The solution should support the ability to “engage in Internet-based education programs, interact with Internet-based government services, and participate in online energy, healthcare and public-safety programs." Many of those things I could do way back in the days of 1200 baud. Is AT&T calling that "broadband?"

To those totally divergent definitions from the commercial players, we have to add the comments from disability agencies. These groups are demanding that any definition of broadband include captioning and video description services for the blind, video relay services, and Internet-based captioned telephone services.

The Center for Democracy and Technology (CDT) wants any broadband definition "to include unrestricted access to the entire Internet." And, even “unrestricted” is not enough for the group, who ends by demanding that any broadband definition should not be an applications-based approach because "basing the definition of broadband on specific services available today could freeze expectations and disincentivize investment in improving networks."

I commend the commission for asking for input. However, and not surprisingly, the responses more resemble a shouting match that produces more confusion than clarity. This isn’t rocket science and, as usual, government is making this way harder than it needs to be.

At this rate, we’ll end up with something designed by committee; everyone’s unhappy, it doesn’t work and costs a fortune.

The FCC should just cut through all this public relations hype and corporate jockeying and declare that, “If it walks like a duck and quacks like a duck, it’s a duck.” Broadband can easily be defined by speed. What you do with it is your business.

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