NCTA Opposed To 100/100 Mbps Symmetrical Broadband Standard

Dec 19, 2023


By Ted Hearn, Editor of Policyband 

Washington, D.C., Dec. 19, 2023 – The trade association for major cable broadband providers is calling on federal regulators to reject ideas that the national Internet speed standard needs to be set at the same high level in both directions or symmetrical.

NCTA - The Internet & Television Association – which represents Comcast and Charter – responded to calls for the Federal Communications Commission to raise the speed definition to 100 Mbps downstream/100 Mbps upstream.

“A number of parties suggest that the [FCC] should move to a symmetrical speedthreshold, such as 100/100 Mbps,” NCTA said in a Dec. 18 filing with the FCC. “The arguments for such an approach are disconnected from the reality of broadband user experience, investment, and deployment and would yield results that have a variety of negative consequences.”

The FCC's current broadband definition is 25/3 Mbps, which most consider in need of upward revision. FCC Chair Jessica Rosenworcel supports 100/20 Mbps as the new standard.

The FCC is preparing a broadband progress report under Section 706 of the Telecommunications Act of 1996 to determine whether broadband is being deployed in a reasonable and timely fashion. In the past, whether deployment was reasonable and timely depended on how many were taking Internet access at acceptable speeds.

A 100/100 Mbps standard would likely omit millions of cable broadband subscribers, who could be considered underserved or perhaps even unserved – a situation that could prompt government-funded overbuilders to enter existing cable broadband service territories.

NCTA’s opposition to a symmetrical standard puts it at odds with several fiber broadband providers.

Last week, Allo Fiber, Google Fiber and Ting Internet sent a letter to the FCC saying that the current definition of broadband – 25/3 Mbps – was outdated and needed to be replaced by higher speed levels. The three fiber providers said they supported a symmetrical broadband definition of 100 Mbps downstream and upstream.

In its comments, NCTA said a symmetrical standard does not reflect subscriber usage, which is heavily asymmetrical in favor of download speeds.

“The weight of the evidence plainly demonstrates that consumer usage has always been highly asymmetrical, and that this pattern has continued in recent years notwithstanding the widespread use of video streaming and the COVID-era shift to greater use of remote work and learning,” NCTA said.

CTIA, the wireless industry's leading trade association, endorsed NCTA’s market-based approach to setting the national definition of broadband based on actual consumer usage patterns.

“Last year, 90% of new home broadband subscribers selected fixed wireless access (FWA) as their solution, even though symmetrical speeds are generally not attainable,” CTIA said in its comments. The [FCC] should not set a standard that arbitrarily diverges from the broadband preferences of the American consumer.”

NCTA also pointed out that a definition of broadband set at 100/100 Mbps symmetrical would distort the true competitive structure of today’s broadband market serving millions of subscribers.

“While the broadband marketplace is as competitive as it has ever been, a competitive analysis using a 100/100 Mbps threshold would show a marketplace with limited competition and fiber providers occupying a dominant position in virtually every geographic area in which they operate,” NCTA said.

Echoing NCTA on setting a market-based speed standard, the Wireless Infrastructure Association (WIA) said setting a 100/100 Mbps standard has implications for the Commerce Department’s Broadband, Equity, Access and Deployment (BEAD) Program.

“The $42 billion allocated for the BEAD program will fund networks capable of providing service at 100/20. If the [FCC] were to adopt a standard in excess of that, it would be declaring these networks obsolete before they even begin to be deployed,” WIA said in its 706 Reports comments yesterday.