Tag: 100/20 Mbps

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Regulation - What is it Good For?

A New Definition of Broadband

The FCC finally increased the definition of broadband from 25/3 Mbps to 100/20 Mbps. The change was too long in coming. This should have been done when Ajit Pai headed the FCC, but politics got in the way. It should have happened when Congress set the definition to 100/20 Mbps in the BEAD grant rules over two years ago – but again, politics interfered.

Coming four or five years too late, the 100/20 Mbps definition of broadband is not only not forward-looking, the new definition of broadband is out of sync with the market. Consider the following table that comes from OpenVault that shows how broadband subscriptions have changed in the country since before the pandemic.

Dec 2019 Dec 2024
Under 50 Mbps 22%  6%
50 – 99 Mbps 24%  4%
100 – 199 Mbps 37% 16%
200 – 499 Mbps 11% 34%
500 – 999 Mbps  4%  7%
1 Gbps  3% 33%

Just before the pandemic, 46% of households were subscribing to speeds under 100 Mbps. Today, only 10% of households buy slower speeds – and many of them are likely in rural areas where they have no other option. The numbers have flipped since the pandemic and 40% of households are now subscribing to speeds of 500 Mbps or faster.

Every time I write a blog about broadband speeds, a few ISPs will respond, saying that people don’t need faster broadband. The first time I heard that sentiment was a unified response from the CEO of every big cable company, who said the same thing when Google upset the market by introducing gigabit broadband. The reality is that it doesn’t matter what people need – what matters is what they are willing to buy. The table above shows that people want to buy faster broadband when given the option. I look at that table, and it’s hard to conclude anything other than the public broadband is something faster than 200 Mbps.

What’s missing in the above chart is any recognition of the importance of upload broadband speeds. I think many consumers who upgrade to faster speeds do so because of issues with upload speeds. Serious gamers and folks who work from home with large data files will tell you that the new 20 Mbps definition of upload broadband is massively obsolete.

Unfortunately, the definition of broadband has political and financial overtones. It determines where grant money can be spent. Upping the definition of broadband also has market consequences. Any ISP that is offering speeds less than 100/20 Mbps today is no longer selling broadband. They might as well be selling dial-up, because even the slow-to-change FCC says that what they are selling is obsolete and is something other than broadband.

It’s hard to say if changing the definition of broadband has any practical impact. It’s possible that this kind of announcement will filter down through the public and cause folks buying slower connections to search for something faster.

The natural question is, what’s the next step in defining broadband? My bet is that the FCC is going to rest on its laurels for a while after finally getting through the politics and making this change. It took nine years to move the definition from 25/3 to 100/20 Mbps. Hopefully, the FCC won’t wait another nine years. Congress already said that 100/20 Mbps is obsolete when it said that federal broadband grants ought to be spent to build gigabit networks. The OpenVault table above says that the public’s desire for gigabit broadband is already here today.

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Regulation - What is it Good For?

FCC Considers New Definition of Broadband

On November 1, the FCC released a Notice of Inquiry that asks about various topics related to broadband deployment. One of the first questions asked is if the definition of broadband should be increased to 100/20 Mbps. I’ve written about this topic so many times over the years that writing this blog almost feels like déjà vu. Suffice it to say that the current FCC with a newly installed fifth Commissioner finally wants to increase the definition of broadband to 100/20 Mbps.

The NOI asks if that definition is sufficient for the way people use broadband today. Of most interest to me is the discussion of the proposed 20 Mbps definition of upload speed. Anybody who follows the industry knows that the use of 20 Mbps to define upload speeds is a political compromise that is not based upon anything other than extreme lobbying by the cable industry to not set the number higher. The NOI cites studies that say that 20 Mbps is not sufficient for households with multiple broadband users, yet the FCC still proposes to set the definition at 20 Mbps.

There are some other interesting questions being asked by the NOI. The FCC asks if it should rely on its new BDC broadband maps to assess the state of broadband – as if they have an option. The answer to anybody who digs deep into the mapping data is a resounding no, since there are still huge numbers of locations where speeds claimed in the FCC mapping are a lot higher than what is being delivered. The decision by the FCC to allow ISPs to report marketing speeds doomed the maps to be an ISP marketing tool rather than any accurate way to measure broadband deployment. It’s not hard to predict a time in a few years when huge numbers of people start complaining about being missed by the BEAD grants because of the inaccurate maps. But the FCC has little choice but to stick with the maps it has heavily invested it.

The NOI asks if the FCC should set a longer-term goal for future broadband speeds, like 1 Gbps/500 Mbps. This ignores the more relevant question about the next change in definition that should come after 100/20 Mbps. According to OpenVault, over 80% of U.S. homes already subscribe to download speeds of 200 Mbps or faster, and that suggests that 100 Mbps download is already behind the market. The NOI should be discussing when the definition ought to be increased to 200 or 300 Mbps download instead of a theoretical future definition change.

Setting a future theoretical speed goal is a feel-good exercise to make it sound like FCC policy will somehow influence the forward march of technology upgrades. This is exactly the sort of thing that talking-head policy folks do when they create 5-year and 10-year broadband plans. But I find it impossible to contemplate that the FCC will change the definition of broadband to gigabit speeds in the next decade, because doing so would be saying that every home that doesn’t have a gigabit option would not have broadband. Without that possibility, setting a high target goal is largely meaningless.

The NOI also asks if the FCC should somehow consider latency and packet loss – and the answer is that of course they should. However, they can’t completely punt on the issue like they do today when FCC grants and subsidies only require a latency under 100 milliseconds and set no standards for packet loss. Setting latency requirements that everybody except high-orbit satellites can easily meet is like having no standard at all.

Of interest to rural folks is a long discussion in the NOI about raising the definition of cellular broadband from today’s paltry 5/1 Mbps. Mobile speeds in most cities have download speeds today greater than 150 Mbps, often faster. The NOI suggests that a definition of mobile broadband ought to be something like 35/3 Mbps – something that is far slower than what a urban folks can already receive. But talking about a definition of mobile broadband ignores that any definition of mobile broadband is meaningless in the huge areas of the country where there is practically no mobile broadband coverage.

One of the questions I find most annoying asks if the FCC should measure broadband success by the number of ISPs available at a given location. This is the area where the FCC broadband maps are the most deficient. I wrote a recent blog that highlighted that seven or eight of the ten ISPs that claim coverage at my house aren’t real broadband options. Absolutely nobody is analyzing or challenging the maps for ISPs in cities that claim coverage that is either slower than claimed or doesn’t exist. But it’s good policy fodder for the FCC to claim that many folks in cities have a dozen broadband options. If it were only so.

Probably the most important question asked in the NOI is what the FCC should do about the millions of homes that can’t afford broadband. The FCC asks if it should adopt a universal service goal. This question has activated the lobbyists of the big ISPs who are shouting that the NOI is proof that the FCC wants to regulate and lower broadband rates. The big ISPs don’t even want the FCC to compile and publish data that compares broadband penetration rates to demographic data and household incomes. This NOI is probably not the right forum to ask that question – but solving the affordability gap affects far more households than the rural availability gap.

I think it’s a foregone conclusion that the FCC will use the NOI to adopt 100/20 Mbps as the definition of broadband. After all, the FCC is playing catchup to Congress, which essentially reset the definition of broadband to 100/20 Mbps two years ago in the BEAD grant legislation. The bigger question is if the FCC will do anything meaningful with the other questions asked in the NOI.

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Regulation - What is it Good For?

Too Little Too Late

On July 25, Chairwoman Jessica Rosenworcel shared with the other FCC Commissioners a draft Notice of Inquiry that would begin the process of raising the federal definition of broadband from 25/3 Mbps to 100/20 Mbps. In order for that to become the new definition, the FCC must work through the NOI process and eventually vote to adopt the higher speed definition.

This raises a question of the purpose of having a definition of broadband. That requirement comes from Section 706 of the Telecommunications Act of 1996 that requires that the FCC make sure that broadband is deployed on a reasonable and timely basis to everybody in the country. The FCC interpreted that requirement to mean that it couldn’t measure broadband deployment unless it created a definition of broadband. The FCC uses its definition of broadband to count the number of homes that have or don’t have broadband.

The FCC is required by the Act to report the status of broadband deployment to Congress every year. During the last week of Ajit Pai’s time as FCC Chairman, he issued both the 2020 and 2021 broadband reports to Congress. Those reports painted a rosy picture of U.S. broadband, partially because progress was measured using 25/3 Mbps definition of broadband and partially because the FCC broadband maps were rife with overstated speeds. The FCC has not issued a report since then, and I can only suppose there aren’t the votes in an evenly split FCC to approve a new report.

To give credit, Chairwoman Rosenworcel tried to get the FCC to increase the definition of broadband to 100/20 Mbps four years ago, but the idea went nowhere in the Ajit Pai FCC. At that time, 100/20 Mbps seemed like a reasonable increase in the definition of broadband. Most cable companies were delivering 100 Mbps download as the basic product, and a definition set at 100/20 Mbps would have made the federal statement that the speeds that most folks buy in cities is a reasonable definition of broadband for everybody else.

Chairwoman Rosenworcel is now ready to try again to raise the definition. Perhaps the possible addition of a fifth Commissioner means this has a chance of passing.

But this is now too little too late. 100/20 Mbps is no longer a reasonable definition of broadband. In the four years since Chairwoman Rosenworcel introduced that idea, the big cable companies have almost universally increased the starting speed for broadband to 300 Mbps download. According to OpenVault, almost 90% of all broadband customers now subscribe to broadband packages of 100 Mbps or faster. 75% of all broadband customers subscribe to speeds of at least 200 Mbps. 38% of households now subscribe to speeds of 500 Mbps or faster.

I have to think that the definition of broadband needs to reflect the broadband that most people in the country are really using. One of the secondary uses of the FCC broadband definition is that it establishes a goal for bringing rural areas into parity with urban broadband. If 75% of all broadband subscribers in the country have already moved to something faster than 200 Mbps, then 100 Mbps feels like a speed that is already in the rearview mirror and is rapidly receding.

When the 25/3 definition of broadband was adopted in 2015, I thought it was a reasonable definition at the time. Interestingly, when I first read that FCC order, I happened to be sitting in a restaurant that was lucky enough to be able to buy gigabit speeds and was sharing it with customers. I knew from that experience that the 25/3 Mbps definition was going to become quickly obsolete because it was obvious that we were on the verge of seeing technology increases that were going to bring much faster speed.

I think the FCC should issue two broadband definitions – one for measuring broadband adoption today and a second definition as a target speed for a decade from now. That future broadband target speed should be the minimum speed required for projects funded by federal grants. It seems incredibly shortsighted to be funding any technology that only meets today’s speed definition instead of the speeds that will be needed when the new network will be fully subscribed. Otherwise, we are building networks that are too slow before they are even finished construction.

Another idea for the FCC to consider could take politics out of the speed definition. Let’s index the definition of broadband using something like the OpenVault speed statistics, or perhaps the composite statistics of several firms that gather such data. Indexing speeds would mean automatic periodic increases to the definition of broadband. If we stick to the current way of defining broadband, we might see the increase in the federal definition of broadband to 100/20 at the end of this year and won’t see another increase for another eight years.

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Regulation - What is it Good For? The Industry

The Latest FCC Maps

As promised, the FCC released a new set of maps on May 30. These are supposed to be the maps that will be used to allocate the $42.5 billion in BEAD grant funding to states. Broadband analyst Mike Conlow quickly published a blog on Substack about the new mapping data that includes a summary of the new map in easy-to-understand tables. Mike’s summary shows that there are more than 114.5 million broadband passings in the country – locations that could be broadband subscribers). That’s an increase of over 1 million locations since the last version of the FCC maps.

More importantly, the new maps can be used to count the number of households that can buy broadband at various speeds. The $42.5 billion in BEAD grant funding will be allocated to states according to the number of unserved locations – places that can’t buy broadband at a speed of at least 25/3 Mbps. Locations are underserved if there is an ISP that offers broadband between 25/3 Mbps and 100/20 Mbps. According to Mike’s quick math, there are 8.67 million unserved locations and 3.55 million underserved locations. Mike subsequently corrected the number of unserved locations to 8.3 million.

Anybody who is intimately familiar with the FCC maps knows that there is a lot of fiction buried in the reporting. There is one huge flaw in the FCC mapping system that has carried over from the previous FCC mapping regime – ISPs self-report the speeds they can deliver. Per the FCC mapping rules, ISPs can claim broadband marketing speeds rather than some approximation of actual speeds. In every county where I’ve delved deep into the local situation, I’ve found multiple ISPs that are overclaiming broadband speeds.

ISPs vary widely in how they report broadband speeds to the FCC. I see some ISPs who meticulously categorize customers into a dozen or more speed tiers. It’s fairly obvious that these ISPs are trying to accurately show the speeds that are available. But there are also ISPs that claim the same speed over a large geographic area. In today’s world, I’m always instantly suspicious of any ISP that claims exactly 100/20 Mbps broadband since that conveniently classifies those locations as served. An ISP making that claim is telling the FCC that everybody in their service footprint already has adequate broadband and that there is no need to give grant money to anybody to compete with them.

But such a claim is ludicrous if the ISP is deploying a technology like DSL, cellular wireless, or fixed wireless where it is impossible that every customer over a wide geographic area to get the ISP’s top claimed speed. Such claims are easy to debunk when you look closely. For example, customers only a few miles from a DSLAM or a tower can’t get the fastest speeds. There are multiple reasons why a given customer’s speed might be slower. Such claims are even more quickly debunked when looking at detailed Ookla speed tests.

A second flaw in the FCC maps is the coverage areas claimed by ISPs. The FCC is counting on public broadband challenges or challenges by State Broadband Offices to somehow fix this problem – but that’s an unrealistic hope. Most people don’t know about the FCC maps and the challenge process – and even people who know about it are not motivated to file a challenge about an ISP that claims service at their home that’s not really available. This issue can apply to any technology, but it’s particularly a problem for WISPs and cellular broadband. It’s not easy for a knowledgeable engineer to accurately judge the coverage area of a wireless network from a given tower – I have to think it’s beyond the capability of the folks at a State Broadband Office to understand it enough to challenge coverage. But it doesn’t take any expertise to know that a WISP or a cellular company claiming ubiquitous 100/20 Mbps coverage across large areas is exaggerating both speed and coverage capabilities.

It’s going to be interesting to see how States react to these final counts. There have been rumors about states ready to sue the FCC and the NTIA if they feel these maps will cheat them out of funding. There has been legislation introduced in the Senate that would force the NTIA to wait longer for better maps before allocating most of the funding. It’s going to be surprising if nobody pops up to challenge the allocation of the $42.5 million dollars. A challenge could pluge the BEAD grants into huge uncertainty.

An even bigger issue is if the FCC maps will be used to determine the locations that are grant eligible – because that would be a travesty. That would mean that every ISP that claims a bogus 100/20 Mbps broadband coverage will be rewarded by keeping out competition from grant funding. Regardless of how the funding is allocated to States, Broadband Offices need to be the ones to determine which locations in their State don’t have good broadband.

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The Industry

Only Twenty Years

I’ve written several blogs that make the argument that we should only award broadband grants based on future-looking broadband demand. I think it is bad policy to provide federal grant funding for any technology that delivers speeds that are already slower than the speeds already available to most broadband customers in the country.

The current BEAD grants currently use a definition of 100/20 Mbps to define who households that aren’t considered to have broadband today. But inexplicably, the BEAD grants then allow grant winners to build technologies that deliver that same 100/20 Mbps speeds. The policymakers who designed the grants would allow federal funding to go to a new network that, by definition, sits at the nexus between served and unserved today. That is a bad policy for so many reasons that I don’t even know where to begin lambasting it.

One way to demonstrate the shortsightedness of that decision is a history lesson. Almost everybody in the industry tosses out a statistic that a fiber network built today should be good for at least thirty years. I think that numbers is incredibly low and that modern fiber ought to easily last for twice that time. But for the sake of argument, let’s accept a thirty-year life of fiber.

Just over twenty years ago, I lived inside the D.C. Beltway, and I was able to buy 1 Mbps DSL from Verizon or from a Comcast cable modem. I remember a lot of discussion at the time that there wouldn’t be a need for upgrades in broadband speeds for a while. The 1 Mbps speed from the telco and cable company was an 18-times increase in speed over dial-up, and that seemed to provide a future-proof cushion against homes needing more broadband. That conclusion was quickly shattered when AOL and other online content providers took advantage of the faster broadband speeds to flood the Internet with picture files that used all of the speed. It took only a few years for 1 Mbps per second to feel slow.

By 2004, I changed to a 6 Mbps download offering from Comcast – they never mentioned the upload speed. This was a great upgrade over the 1 Mbps DSL. Verizon made a huge leap forward in 2004 and introduced Verizon FiOS on fiber. That product didn’t make it to my neighborhood until 2006, at which time I bought a 30 Mbps symmetrical connection on fiber. In 2006 I was buying broadband that was thirty times faster than my DSL from 2000. Over time, the two ISPs got into a speed battle. Comcast had numerous upgrades that increased speeds to 12 Mbps, then 30 Mbps, 60 Mbps, 100 Mbps, 200 Mbps, and most recently 1.2 Gbps. Verizon always stayed a little ahead of cable download speeds and continued to offer much faster upload speeds.

The explosion of broadband demand after the introduction of new technology should be a lesson for us. An 18-time speed increase from dial-up to DSL seemed like a huge technology leap, but public demand for faster broadband quickly swamped that technology upgrade, and 1 Mbps DSL felt obsolete almost as soon as it was deployed. It seems that every time there has been a technology upgrade that the public found a way to use the greater capacity.

In 2010, Google rocked the Internet world by announcing gigabit speeds. That was a 33-time increase over the 30 Mbps download speeds offered at the time by the cable companies. The cable companies and telcos said at the time that nobody needed speeds that fast and that it was a marketing gimmick (but they all went furiously to work to match the faster fiber speeds).

I know homes and businesses today that are using most of the gigabit capacity. That is still a relatively small percentage of homes, but the number is growing. Over twenty years, the broadband use by the average home has skyrocketed, and the average U.S. home now uses almost 600 gigabytes of broadband per month – a number that would have been unthinkable in the early 2000s.

I look at this history, and I marvel that anybody would think that it’s wise to use federal funds to build a 100/20 Mbps network today. Already today, something like 80% of homes in the country can buy a gigabit broadband product. The latest OpenVault report says that over a quarter of homes are already subscribing to gigabit speeds. Why would we contemplate using federal grants to build a network with a tenth of the download capacity that is already available to most American homes today?

The answer is obvious. Choosing the technologies that are eligible for grant funding is a political decision, not a technical or economic one. There are vocal constituencies that want some of the federal grant money, and they have obviously convinced the folks who wrote the grant rules that they should have that chance. The biggest constituency lobbying for 100/20 Mbps was the cable companies, which feared that grants could be used to compete against their slow upload speeds. But just as cable companies responded to Verizon FiOS and Google Fiber, the cable companies are now planning for a huge leap upward in upload speeds. WISPs and Starlink also lobbied for the 100/20 Mbps grant threshold, although most WISPs seeking grant funding are now also claiming much faster speed capabilities.

If we learn anything from looking back twenty years, it’s that broadband demand will continue to grow, and that homes in twenty years will use an immensely greater amount of broadband than today. I can only groan and moan that the federal rules allow grants to be awarded to technologies that can deliver only 100/20 Mbps. But I hope that state Broadband Grant offices will ignore that measly, obsolete, politically-absurd option and only award grant funding to networks that might still be serving folks in twenty years.

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Regulation - What is it Good For?

A New Definition of Broadband?

FCC Chairman Jessica Rosenworcel has circulated a draft Notice of Inquiry inside the FCC to kick off the required annual report to Congress on the state of U.S. broadband. As part of preparing that report, she is recommending that the FCC adopt a new definition of broadband of 100/20 Mbps and establish gigabit broadband as a longer-term goal. I have a lot of different reactions to the idea.

First, the FCC is late to the game since Congress has already set a speed of 100/20 Mbps for the BEAD and other federal grant programs. This is entirely due to the way that the FCC has become totally partisan. Past FCC Chairman Ajit Pai was never going to entertain any discussion of increasing the definition of broadband since he was clearly in the pocket of the big ISPs. The FCC is currently split between two democrats and two republicans, and I find it doubtful that there can be any significant progress at the FCC on anything related to broadband in the current configuration. I have to wonder if the Senate is ever going to confirm a fifth commissioner – and if not, can this idea go anywhere?

Another thought that keeps running through my mind is that picking any speed as a definition of broadband is completely arbitrary. We know in real life that the broadband speed to a home changes every millisecond, and speed tests only take an average of the network chaos. One of the things we found out during the pandemic is that jitter might matter more than speed. Jitter measures the variability of the broadband signal, and a customer can lose connectivity on a network with high jitter if the speed drops too low, even for a few milliseconds.

I also wonder about the practical impact of picking a definition of speed. Many of the current federal grants define a served customer as having an upload speed of at least 20 Mbps. It’s clear that a huge number of cable customers are not seeing 20 Mbps upload speeds, and I have to wonder if any State broadband offices will be brave enough to suggest using federal grant funding to overbuild a cable company. If not, then a definition of broadband as 20 Mbps upload is more of a suggestion than a rule.

Another issue with setting definitions of speed is that any definition of speed will define some technologies as not being broadband. That brings a lot of pressure from ISPs and manufacturers of these technologies. This was the biggest problem with the 25/3 Mbps and DSL. While it is theoretically possible to deliver 25/3 Mbps broadband on a single copper wire, the big telcos spent more than a decade claiming to meet speeds that they clearly didn’t and couldn’t deliver. We’re seeing the same technology fights now happening with a 100/20 Mbps definition of broadband. Can fixed wireless or low orbit satellite technology really achieve 100/20 Mbps?

Another issue that has always bothered me about picking a definition of broadband is that the demand for speed has continued to grow. If you define broadband by the speeds that are needed today, then that definition will soon be obsolete. The last definition of broadband speed was set in 2015. Are we going to wait another seven years if we change to 100/20 Mbps this year? If so, the 100/20 Mbps definition will quickly become as practically obsolete as happened with 25/3.

Finally, a 100/20 Mbps speed is already far behind the market. Most of the big cable companies have recently declared their basic broadband download speed to be 200 Mbps. How can you set a definition of broadband that has a slower download speed than what is being offered to at least 65% of the households in the country? One of the mandates given to the FCC in the Telecommunications Act of 1996 was that rural broadband ought to be in parity with urban broadband. Setting a definition of broadband only matters for customers who don’t have access to good broadband. Do we really want to use federal money in 2022 to build 100 Mbps download broadband when a large majority of the market is already double that speed today?

Trying to define broadband by a single speed is a classical Gordian knot – a problem that can’t be reasonably solved. We can pick a number, but by definition, any number we choose will fail some of the tests I’ve described above. I guess we have to do it, but I wish there was another way.

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Regulation - What is it Good For?

Future-proofing Grants

There has been a lot of discussion in the last few months about how wonderful it was for Congress to have increased the speed requirements for broadband grant eligibility to 100/20 Mbps in the $42.5 billion BEAD grants. But is it really all that wonderful?

It’s obvious that the FCC’s definition of broadband of 25/3 Mbps is badly out of date. That definition was set in 2015, and it seemed like an adequate definition at the time. If we accept that 25 Mbps was a good definition for download speed in 2015 and that 100 Mbps is a good definition in 2022, then that is an acknowledgment that the demand for download broadband speed has grown at about 21% per year, which is shown in the table below.

Historic Download Speed Demand in Megabits / Second

2015 2016 2017 2018 2019 2020 2021 2022
25 30 37 44 54 65 79 95

We have outside evidence that the 21% growth rate makes sense. Several times over the last decade, both Cisco and Opensignal opined that the residential demand for download speed has been growing at that same 21% rate. Cisco said that it thought business demand was growing at about a 23% clip.

This raises an interesting question of how good it is for a grant program today to use a 100 Mbps definition for broadband? The main reason that this is a relevant question is that the BEAD grants aren’t going to be constructed for many years. My best guess is that the majority of BEAD grants will be awarded in 2024, and ISPs will have four more years to finish network construction – until 2028. The above table shows how much broadband demand for download speed grew from 2015 until 2022. What might this look like by the time the BEAD networks are fully implemented?

Future Projected Download Speed Demand in Megabits / Second

2022 2023 2024 2025 2026 2027 2028
100 121 146 177 214 259 314

If we accept that 100 Mbps download is adequate today as a definition of download broadband speed, then if broadband demand continues to grow at 21% annually, the definition of download broadband ought to be over 300 Mbps in 2028. I know many cynics will say that broadband demand cannot continue to grow at the historic rate, but those same people would have said the same thing in 2015 – and been proven wrong. In fact, there has been a steady growth curve for broadband speed demand back into the 1980s. There is no evidence I’ve heard that would indicate that the demand growth has slowed down.

We don’t really need to have this theoretical discussion of adequate broadband speeds because the market is ahead of the above speed growth curves. Since the early 2000s, cable companies have unilaterally raised the speed of basic broadband to keep ahead of the demand curve. The cable companies have raised minimum speeds every few years as an inexpensive way to keep customers happy with cable broadband.

The cable industry is in the process right now of increasing the speed of basic download speed to 200 Mbps – a number higher than predicted by the table above for 2022. There is a strong argument to be made that the cable companies have been resetting the definition of broadband while regulators were too timid to do so. I can remember when the cable companies collectively and unilaterally increased speeds to 6 Mbps. 12 Mbps, 30 Mbps, 60 Mbps, 100 Mbps, and now 200 Mbps.

This argument is further strengthened when considering that the big cable companies serve almost 70% of all broadband customers in the country today. When Congress gave the FCC responsibility for broadband in the 1996 Telecommunications Act, the requirement that the FCC has largely shoved under the rug was that rural broadband should be in parity with urban broadband. If 70% of new broadband subscribers in the U.S. are offered 200 Mbps broadband as the slowest basic product, it’s hard to argue that having a definition of anything under 200 Mbps today is not parity.

Congress wasn’t all that brave in setting the definition of grant-eligible at 100/20 Mbps. That is the lowest possible current definition of download speeds, and a number that is already starting to drift to be obsolete. Recall the gnashing of teeth in the industry last year while the legislation was being created – cable companies and WISPs both thought that 100/20 Mbps was too aggressive.

If we really wanted to future-proof the BEAD grants, then technology that won’t be built until 2028 should be required to deliver at least 300 Mbps download. Anything less than that means networks that the public will feel are inadequate as they are being deployed.

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Uncategorized

An Easier Way to Define Broadband

Our broadband policies always seem to lag the market. If and when the FCC seats the fifth Commissioner, it’s expected that the agency will raise the definition of broadband from 25/3 Mbps to 100/20 Mbps. That change will have big repercussions in the market because it will mean that anybody that can’t buy broadband speeds of at least 100/20 Mbps would not have broadband. That’s how an official broadband definition works – you either have broadband, or you don’t.

The definition of broadband matters for several reasons. First, it makes areas that don’t have broadband eligible for federal grants – although many of the current round of big grants did not wait for the FCC to change the definition of broadband. It also matters in how we count the number of people without broadband. That has supposedly been one of the major purposes of the FCC broadband maps, and they failed badly in identifying homes that can’t buy 25/3 broadband. But on the day that the FCC changes the definition of broadband, millions of homes will be officially declared to not be able to buy real broadband.

I’ve always hated these arbitrary hard lines defined by speeds. Anybody who has ever done speed tests at their home knows that the broadband speed delivered varies from second to second, minute to minute, and hour by hour. It’s not unusual at my desk to see speeds vary by more than 50% during the course of the day.

The original purpose for having a definition of broadband was established by Congress, which directed the FCC to have plans to bring rural broadband into parity with urban broadband. The folks that wrote that law in 1996 could never have envisioned that we’d grow from having dial-up Internet to gigabit capabilities in urban America in 2022.

If the goal is still to create parity between urban and rural broadband, there is a much easier way to define broadband. The cable companies have regularly increased the speeds of their minimum broadband products, and in my mind, when they do so, they set a new standard target for parity between rural and urban areas.

Recently both Charter and Cable One increased the minimum speeds of basic broadband to 200 Mbps (with no mention of upload speeds). Charter is increasing speeds automatically with no rate changes. Cable One’s change seems like more of a quiet rate increase since it will charge customers $5 more per month to automatically move them from 100 Mbps to 200 Mbps.

Charter has always led the industry in this. I think they were a leader in moving to 30 Mbps, 60 Mbps, 100 Mbps, and now 200 Mbps. The rest of the cable industry generally matches Charter in this increases within a year or so.

The one exception is Comcast Xfinity. The company still has a 50Mbps and a 100 Mbps product. However, if you go to the web, all they are pushing is a new 300 Mbps product. I expect it’s not easy for a new customer to buy the 50 Mbps product.

When the big cable companies voluntarily raise the speed bar by increasing speeds across the board, they have, by definition, redefined urban broadband. Can parity mean anything other than residents in a rural area should be able to buy broadband as fast as is available to a basic broadband customer in an urban area?

Maybe I’m being too simplistic, but if the FCC finally raises the definition of broadband this year to 100/20 Mbps, it will already be lagging behind the urban broadband market with that definition.

Of course, the download speed question is only half of the speed equation. You have to dig deep on cable company websites to find any mention of upload speeds. The cable companies lobbied extremely hard during the passage of broadband grant legislation to make certain that the upload speed definition for grant purposes didn’t go higher than 20 Mbps. When cable companies talk to customers, they are moot on upload speeds since few urban cable products actually deliver 20 Mbps.

I probably have written too many blogs about the definition of broadband. But it’s a topic that keeps having real-life implications. It’s ludicrous that there are still federal grants that award more money for serving areas with broadband speeds under 25/3 Mbps. If the real goal of the federal government is to have parity between rural and urban broadband speeds, then Charter and Cable One just provided us with a new definition of broadband. If somebody uses federal grant money to build a rural market with 100 Mbps download technology, it’s already out of parity in 2022, and it’s hard to imagine how far it will be out of parity by the time the grant-funded network is built and operational.

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Regulation - What is it Good For?

The New Speed Battle

I’ve been thinking about the implications of having a new definition of broadband at 100/20 Mbps. That’s the threshold that has been set in several giant federal grants that allow grant funding to areas that have broadband slower than 100/20 Mbps. This is also the number that has been bandied about the industry as the likely new definition of broadband when the FCC seats a fifth Commissioner.

The best thing about a higher definition of broadband is that it finally puts the DSL controversy to bed. A definition of broadband of 100/20 Mbps clearly says that DSL is no longer considered to be broadband. A 100/20  Mbps definition of broadband means we can completely ignore whatever nonsense the big telcos report to the FCC mapping process.

Unfortunately, by killing the DSL controversy we start a whole new set of speed battles with cable companies and WISPs that will be similar to the controversy we’ve had for years with DSL. Telcos have claimed 25/3 Mbps broadband coverage over huge parts of rural America in an attempt to deflect broadband grants. In reality, there is almost no such thing as a rural customer who can get 25/3 Mbps DSL unless they sit next to a DSLAM. But the telcos have been taking advantage of the theoretical capacity of DSL, and the lax rules in the FCC mapping process allowed them to claim broadband speeds that don’t exist. I hate to admit it, but overstating DSL speeds has been a spectacularly successful strategy for the big telcos.

We’re going to see the same thing all over again, but the new players will be cable companies and WISPs. The controversy this time will be more interesting because both technologies theoretically can deliver speeds greater than 100/20 Mbps. But like with DSL, the market reality is that there are a whole lot of places where cable companies and WISPs are not delivering 100/20 Mbps speeds and would not be considered as broadband with a 100/20 Mbps yardstick. You can take it to the bank that cable companies and WISPs will claim 100/20 Mbps capability if it helps to block other competitors or if it helps them win grants.

The issue for cable companies is the upload speed. One only has to look at the mountains of speed tests gathered around the country to see that cable upload speeds are rarely even close to 20 Mbps. We’ve helped cities collect speed tests where maybe 5% of customers are reporting speeds over 20 Mbps, while the vast majority of cable upload speeds are measured at between 10 Mbps and 15 Mbps. Usually, the only cable customers with upload speeds over 20 Mbps are ones who have ponied up to buy an expensive 400 Mbps or faster download product – and even many of them don’t see upload speeds over 20 Mbps.

This begs the question of what a definition of broadband means. If 95% of the customers in a market can’t achieve the defined upload speeds, is a cable company delivering broadband under a 100/20 Mbps definition? We know how the telcos answered this question in the past with DSL, and it’s not hard to guess how the cable companies are going to answer it.

It’s not a coincidence that this new controversy has materialized. The first draft of several of the big grant programs included a definition of broadband of 100/100 Mbps – a speed that would have shut the door on cable companies. But cable company lobbying began immediately, and the final rules from Congress included the slimmed-down 100/20 Mbps broadband definition.

WISPs have a more interesting challenge because the vast majority of existing WISP connections are nowhere close to meeting either the upload or download speed of 100/20 Mbps. But fixed wireless technology is capable of meeting those speeds. A WISP deploying a new state-of-the-art system can achieve those speeds today for some reasonable number of miles from a tower in an area with good lines of sight. But most existing WISPs are deploying older technology that can’t come close to a 100/20 Mbps test. Even WISPs with new technology will often serve customers who are too far from a tower to get the full speeds. Just like with cable companies, the 100/20 Mbps definition of broadband will allow WISPs to stay in the game to pursue grants even when customers are not receiving the 100/20 Mbps speeds. So brace yourself, because the fights over speeds are far from over.

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