The Telecommunications Industry Association (TIA) has submitted comments in response to the Federal Communication Commission's Public Notice seeking comments on the definition of "Broadband." "We suggest that the Commission not limit itself to one narrow and arbitrary definition of broadband," said TIA Vice President of Government Affairs, Danielle Coffey. "Since many technologies play a critical role in the broadband market, TIA supports a tiered speed analysis, which recognizes the diverse uses and benefits of broadband and broadband-enabled products and services and would allow the Commission to take into account current and future technologies."

The request for comments on the definition of broadband is designed to assist the Commission in development of a National Broadband Plan pursuant to the American Recovery and Reinvestment Act (ARRA) of 2009 and related purposes. TIA's efforts to define the term are aligned with the Commission's efforts to incorporate the use of broadband infrastructure and services in advancing a broad array of public interest goals, including 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.

"Because broadband speeds may vary depending on many factors, we suggest that the Commission focus on the demand or requirements of a given application and craft tiers in a manner that allows for the use of all technologies to achieve various policy goals," said Coffey. TIA also asserts that any definition of broadband must include two-way transmission capability. But the quality of a consumer's experience is not only determined by speed. Latency, or the time it takes for a packet of data to get from point to point, also may affect the end-user experience, since different applications vary in latency requirements." TIA also continues to advocate that a "minimum" broadband speed should consider the varying attributes of wireless versus wireline technologies, each of which have their own distinct benefits, thus rendering inappropriate a speed comparison of the two without taking into consideration many other factors. In its letter, TIA urged the Commission to balance the benefits of driving an infrastructure designed for both current and future needs with the ability of the nation to cost-effectively provide the technologies. The association recommended that any definition of broadband be crafted around recognition of tiers of service, capabilities and offerings, with an explicit reference to two-way transmission capability.