Have an opinion on broadband caps? Speeds? Tell the FCC.

FCC Chairman Julis Genachowski

The Federal Communications Commission is seeking insights on how slow a broadband connection can be and still be considered broadband, as well as what would constitute a reasonable data cap. In a notice of inquiry (formal FCC speak for “send us your comments”) the regulatory agency asked Tuesday if the current definition of broadband is too slow for how people currently use their connections, and if it needs to establish guidelines for data caps.

The inquiry also asked about mobile broadband speeds and caps as well as latency and other topics. But the important thing here is that the FCC seems to be recognizing that the 4 Mbps download/1 Mbps upload minimum standard for broadband isn’t so useful anymore — not with multiple people in a household all trying to watch Netflix and make video calls at the same time. From the notice:

The bandwidth requirements of a household can increase as the number of devices sharing a broadband connection increases, particularly if multiple users are accessing video content with that connection. How should this usage pattern affect our speed threshold analysis?

That’s a great question, but better ones should be asked, especially when it comes to the topic of bandwidth caps — something FCC Chairman Julius Genachowski has said he thinks are acceptable. But in the inquiry, which seems to stem in part from soul-searching done after the FCC had to say for the third year in a row that the U.S. wasn’t deploying broadband in a reasonable and timely fashion, the FCC asks whether caps on broadband should affect how it ranks ISPs. From the report:

If we add a data capacity threshold for fixed broadband in the next report, what data capacity threshold or thresholds should we adopt? What data capacity limits do most fixed broadband providers offer today? How often, and under what circumstances, do consumers exceed these limits? What reliable data sources exist to identify providers’ offerings and consumers’ use? How should we evaluate situations where a provider offers more than one data capacity package to its consumers at a different price or using a different technology?

Right now the FCC has apparently considered a cap of 250 GB per month as a reasonable cap in urban areas, but I’d be curious how it came to this conclusion. Did it just pick that number after Comcast implemented that in 2008 as its original data cap, or did it actually perform some kind of analysis and then dispense that to the industry? And while it is asking questions about caps, I’d like to have the FCC ask the ISPs to explain how a data cap helps them manage their network and deal with congestion as well as why those caps need to be there in the first place. See, I have questions of my own.

The nice thing is anyone can send comments to the FCC answering the questions it raised in this notice as long as they do so before Sept. 20. To respond to the inquiry, write up your thoughts and then head over to the FCC’s Electronic Filing Comment System. Enter the proceeding number 12-228, and then you fill out the form and upload your comments. Good luck!

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