Defining Broadband
Comments submitted in response to the FCC request for how to define broadband.27-Aug-2009

Comments I submitted in response to http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-1842A1.pdf.

Comments on Defining “Broadband” Dockets 09-47, 09-51, 09-137

Submitted by: Robert (Bob) Frankston – FCC-Submission@BobF.Frankston.com

I am concerned that the request presumes that broadband is the answer and that it’s just a matter of details like speed. It doesn’t allow for consideration of the more fundamental issues I write about in http://frankston.com/?name=BroadbandInternet. Trying to frame the issue in terms of requirements for existing applications misses the entire point of the Internet as a phenomenon. The answer is not in the network – the answer should be in what we can do with connectivity but as long as we make broadband services the gating factor we can only choose from the past and not create the future.

We forget that the Web (as one driver for extending connectivity) happened because of dial-up modems. I remember trying to explain to others at Microsoft why 2400bps (at that time) was far more important than multimegabit interactive TV. It’s all about the marketplace dynamic (AKA the funding model or the money trail). Over-defining the solution assures a failure of the dynamic. I write about this dynamic in http://frankston.com/?n=InternetDynamic. I observed that the surest way to have killed VoIP would have been to make it a requirement.

The good news is that today’s funding model is showing its age. Andy Kessler’s recent Wall Street Journal op-ed is one indicator. What happens when iTunes gives you access to all of “cable” content – Hulu (http://hulu.com) is just nibbling at the edges and has already had a significant impact with CPM even higher than broadcast.

I compare the current telecom business model to trying to profit from the differential in pricing between the 59th St Bridge and the Queensboro Bridge. It fails once people understand that it’s the same bridge – just like bits are bits. Eliminating spurious billable events could contribute many billions to the economy each year and we get much more by creating opportunity. More “Broadband” will not have a transformational impact because we can’t assume connectivity – only sell old stuff to more subscribers.

The FCC faces a dilemma. It regulations are defined on the premise that telecommunications is a service business. Digital technology has changed the game. We can create those services ourselves using commodity bits. We need infrastructure not service providers.

In defining “broadband” we need to challenge the implicit assumptions rather than answer the question as framed. The question is not what “broadband” is, the question is what is the new mission for the FCC?