FOR IMMEDIATE RELEASE
October 02, 2009
Washington, D.C. – In response to the FCC's request for comments following its Sept. 2 workshop on broadband metrics, the Telecommunications Industry Association (TIA) filed comments recommending that the Commission develop a tiered analysis for defining two-way broadband speeds that accounts for all technologies and the capabilities they promote.
TIA is also recommending that the Commission encourage and facilitate more consumer disclosure in regard to their broadband plan that extends beyond advertised speeds.
"This type of approach will allow the Commission to focus on the public policy objectives enabled by broadband rather than focusing on one narrow and arbitrary definition," said Danielle Coffey, TIA Vice President for Government Affairs. "A tiered speed analysis allows the Commission to take into account current and future technologies and recognizes the diverse uses and benefits of broadband and broadband-enabled products and services."
In an effort to achieve these goals and develop a tiered analysis, TIA encouraged the Commission to focus on the demand or requirements of a given application.
"The Commission should also take into account that the ability to deliver end-to-end capacity and the appropriate applications encompasses more than the first mile technology," said Coffey. "The Commission should then craft tiers in a manner that allows for the use of all technologies to achieve various policy objectives. This approach will allow the Commission to avoid attaching goals to speeds not capable or that are not necessary for delivering the application or service required to meet that particular goal."
TIA also continues to assert that any definition of broadband must include two-way transmission capability, though not necessarily that it must be symmetric. Each tier should identify a downlink speed and a proportional uplink speed.
"In order to craft these tiers, the Commission must have a thorough understanding of the capabilities of current and future technologies and how they are being used to achieve the public policies goals enumerated for the National Broadband Plan, such as consumer welfare, civic participation, public safety and homeland security, community development, health care delivery, energy independence and efficiency, education, worker training, private sector investment, entrepreneurial activity, job creation and economic growth, and other national purposes."
TIA is now also recommending that the Commission encourage and facilitate more consumer disclosure in regard to their broadband plan that extends beyond advertised speeds.
"Regardless of the metrics used to define broadband, whether it be minimum speeds or latency requirements, the Commission should encourage increased disclosure on these issues," said Coffey. "TIA has continually advocated that consumers should receive meaningful disclosure of information regarding their broadband service plans. Increased disclosure on quality parameters that affect a consumer's broadband service, such as latency or delivered (versus advertised) speeds, will facilitate a greater understanding on behalf of consumers when choosing their service.
"Currently, information on a broadband plan is provided in terms of the speeds a network can deliver at optimal performance. However, this is not usually the speed the consumer receives on average, and service providers do not include information on latency or other technical factors that can affect the quality of service. Disclosure on these issues will only serve to empower the consumer in making an informed decision when choosing a broadband service."
TIA's comments filed today are available on the FCC filings page at tiaonline.org.
For more information about TIA's government affairs initiatives, please contact Danielle Coffey at dcoffey@tiaonline.org.
Sign up for RSS feeds on TIA news.
About TIA
The Telecommunications Industry Association (TIA) represents the global information and communications technology (ICT) industry through standards development, advocacy, tradeshows, business opportunities, market intelligence and world-wide environmental regulatory analysis. With roots dating back to 1924, TIA enhances the business environment for broadband, mobile wireless, information technology, networks, cable, satellite and unified communications. Members' products and services empower communications in every industry and market, including healthcare, education, security, public safety, transportation, government, the military, the environment and entertainment.
TIA co-owns the SUPERCOMM® tradeshow and is accredited by the American National Standards Institute (ANSI). Visit tiaonline.org.
TIA's Board of Directors includes senior-level executives from ACS, ADC, ADTRAN, Alcatel-Lucent, ANDA Networks, AttivaCorp, Avaya, Bechtel Communications, Inc., Cisco Systems, Corning Incorporated, Ericsson, Inc., GENBAND, Inc., Graybar, Henkels & McCoy, ILS Technology, Intel Corporation, Intersect, Inc., LGE, Microsoft, Motorola, Nokia Siemens Networks, Nortel, Openwave, Inc., Panasonic Computer Solutions Co., Powerwave Technologies, Qualcomm, Research In Motion, Sumitomo Electric Lightwave Corporation, Tellabs, Tyco Electronics, Ulticom, Inc., and Verari Systems. Advisors to the Board include FAL Associates, Orca Systems and Telcordia Technologies.
##