The NCTA – The Internet & Television Association has urged the FCC to reject proposals to raise national broadband speeds standards to a symmetrical 100 Mbit/s, arguing in part that typical usage patterns remain largely asymmetrical.

Several parties, including Google Fiber, Allo Fiber and Ting Internet, have suggested that the FCC raise broadband speed definitions to a symmetrical 100 Mbit/s, up from today's standard of 25 Mbit/s downstream by 3 Mbit/s upstream. The current definition, they argued, "is outdated and no longer meets the needs of consumers … The 25/3 Mbps definition of broadband was adopted in 2015, and was even then considered obsolete by many commentators. It is even more obsolete now."

The FCC's notice of inquiry into the matter proposes to increase the minimum broadband speed definition to 100 Mbit/s downstream and 20 Mbit/s upstream and to set up a separate national goal of 1 Gbit/s by 500 Mbit/s for the future.

Arguments for 100/100 speed standard 'are disconnected from the reality'

In reply comments filed December 18, NCTA said it recognized that there's broad support for the FCC to raise the speed threshold. But the organization, which represents major US cable operators such as Comcast and Charter Communications, argued that resetting the definition at 100 Mbit/s by 100 Mbit/s is a bridge too far.

"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 NCTA explained. "As NCTA and others explained, 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."

And any implication that US broadband networks "were not up to the task of dealing with the demands of the pandemic has been conclusively proven wrong," the organization added.

NCTA also argued that a 100/100 Mbit/s threshold "would substantially understate the presence of services that are purchased by tens of millions of households today" and "show a marketplace with limited competition and fiber providers occupying a dominant position in virtually every geographic area in which they operate."

Potential impact on broadband subsidy programs

The organization also held that a new symmetrical 100 Mbit/s standard could undermine the FCC's subsidy initiatives, as well as the Broadband Equity, Access and Deployment (BEAD) program, and potentially lead to "wasteful overbuilding" in areas where high-speed broadband services already exist.

As one example, the $18 billion recently committed to the Enhanced ACAM program for the delivery of speeds of 100 Mbit/s down by 20 Mbit/s "would have to be considered a complete waste of money because, under a 100/100 Mbps benchmark, the program would not mandate qualifying service at a single unserved location," the NCTA argued.

"We think a far more rational approach is to follow recent Commission precedent and adopt a speed threshold that is tied to the statutory definition and that respects the choices made by consumers, who are overwhelmingly satisfied with the performance of the services they already purchase," the NCTA said.

The vast majority of US cable's widely deployed hybrid fiber/coax (HFC) networks are already set up to easily exceed a proposed 100 Mbit/s downstream standard, but will likely require some additional work to in order to hit a 100 Mbit/s upstream threshold.

Well ahead of future DOCSIS 4.0 deployments that will support symmetrical multi-gigabit speeds, several cable operators have initiated "mid-split" and "high-split" upgrades that dedicate more spectrum to the HFC upstream. Among specific examples, Charter  Communications' multi-phase network evolution plan, which includes DOCSIS 4.0 network upgrades in a portion of its footprint, aims to support speeds of 1 Gbit/s in the upstream direction.