The cable industry is suggesting that the Federal Communications Commission define “broadband” not for what it is, but for what it does – enable access to services such as e-mail and Web browsing.

Beginning in 1996, the FCC has employed a definition of broadband that specifies a minimum of 200 kbps in at least one direction. That definition has been derided as inadequate since the turn of the century. The FCC intends to update the definition and has asked for advice.

The National Cable & Telecommunications Association has just circulated its response, advising that again enshrining specific performance parameters (including not only speed, but also latency, jitter, symmetrical transmission and other measurements) will be repeating a mistake.

Instead, the FCC should keep its current definition of broadband from its Form 477 (which in its extant form continues to include the 200 kbps parameter). 

The NCTA’s recommendation reads: “The Commission should not use the process of defining ‘broadband’ as a vehicle for imposing substantive obligations on providers of broadband services. Rather, as Congress did in defining terms like ‘cable service,’ ‘telecommunications service’ and ‘information service,’ the Commission should adopt a more generic definition that focuses on the core functionality of the service. It should address separately what obligations, if any, should be imposed on providers of the service.”

Some have suggested that the definition of broadband evolve as speeds available increase. Consistent with its position that specific parameter not be part of the definition, the NCTA disagrees.

“The desire for continual improvement in national broadband performance is a worthy goal, but a constantly evolving definition of ‘broadband’ is not necessary or helpful to achieving that goal. Rather than changing the definition of ‘broadband’ every year, the Commission should incorporate the existing definition and speed tiers into goals based on the percentage of households and businesses with access to service in a particular tier.”