At a Joint Center for Political and Economic Studies meeting earlier this week, FCC Chairman Genachowski noted that America must measure our broadband progress not only by the ability to extend access to every home, but also by our success in encouraging minority communities, low-income families and under-privileged communities to make broadband part of their lives.

We couldn’t agree more.  We have consistently argued that the combination of creative ways to spur investment in deployment, coupled with a strong programmatic focus on adoption, was priority #1.  See my video blog from January here making these points.   And it is why we are pleased to partner with nearly 100 other organizations this week to launch a new coalition – called Broadband for America – with a simple yet challenging goal:  ensuring that broadband is available to, and used by, every household and business in America.

We have a very clear view about all this:  Extraordinary private investment is what created, built, and sustains the future of broadband.   Government policy should recognize this overarching reality and continue to support this framework.  On the other hand, broadband adoption, while an amazing success with 63 percent of America connected, probably starts to get harder now and it will take a collaborative effort by all stakeholders, industry, civic groups, and government alike, to get to where we want to go.

Ten years ago, the cable industry made a commitment to bring broadband to consumers in the markets we serve, and our industry has already invested more than $145 billion so that 92 percent of all U.S. households can choose a cable broadband offering.  Other telecom providers have spent hundreds of billions to deliver competitive broadband as well and the number of wired and wireless choices is steadily growing.

But in addition to our investment in fiber optics, routers and facilities, we are helping to close the adoption gap by partnering with civic, community and consumer organizations with a variety of projects that aim to jumpstart broadband use among diverse communities.

Through Cable in the Classroom, we’ve been a longtime leader in enabling consumers to use technology to enhance and expand learning.  Our industry in the late 1980’s began wiring schools and libraries nationwide – originally providing free video service to more than 80,000 sites – but as our industry began deploying broadband in the late 90’s, operators installed broadband connections in thousands of schools and libraries across the country… typically for free.

Cable companies have also initiated unique community-based partnerships with a wide variety of organizations, developing programs that provide computers to low-income families; train senior citizens about how to use computers, email and the Internet; power inner-city computer labs that connect at-risk students and adults to essential online resources; and improve health care by enabling rural hospitals to quickly transmit high-resolution images to specialists worldwide.  Various cable companies have formed great and sustained relationships with organizations like the Boys and Girls Clubs, City Year and One Economy to pursue these goals.  Hundreds of these effective partnerships exist in communities large and small across the U.S.  But we’ll need hundreds more.

Over the coming weeks and months, Broadband for America will be telling a story that doesn’t get the attention it deserves because it doesn’t lend itself to provocative headlines.  And, that is that the deployment of broadband has been an amazing American success story of investment, innovation, and creativity, and that all of us – industry, government and civic groups – are committed to making it better.   Look for us to get the word out.  But this is an interactive program – bring your best ideas on how to promote broadband adoption to www.broadbandforamerica.com and help us take on this challenge.

Yesterday, during a speech at the Brookings Institute, FCC Chairman Julius Genachowski proposed new rules that would affect Internet access providers.

Saying the FCC must be a "smart cop on the beat preserving a free and open Internet," FCC Chairman Julius Genachowski Monday proposed adding two new Internet access principles to the existing four, and will begin the process of codifying all of them with a Notice of Proposed Rulemaking at the FCC’s October meeting.

In a written statement, NCTA’s President & CEO Kyle McSlarrow applauded Genachowski’s "vision of preserving an open Internet in order to promote entrepreneurship without permission." He reiterated the cable industry’s commitment "to an open Internet that allows consumers to use and enjoy lawful content and services of their choosing."

He also said:

We recognize that we may, however, have a different view about the state of competition and the choices and benefits that flow to consumers from that competition.  While we look forward to working with Chairman Genachowski and his colleagues, we will continue to present facts and data to the Commission that suggest that any regulation in this arena should be approached with great caution and only in the most targeted way, and to advocate policies that avoid government entanglement in operational decisions that could undermine the very dynamism of the Internet we all seek to preserve.

David L. Cohen, on the Comcast Voices blog, also indicated their support for the process.

We welcome the dialogue suggested by the Chairman in his comments, and we completely agree that any consideration of new “rules of the road” begin with notice and an open, public rulemaking proceeding – this is both fair and appropriate.

A tweet from Julian Sanchez yesterday raised an interesting point. There are those who may object to any government regulation at all. There are also those who may reflexively support any regulation that seems to be opposed by "big companies."

Previously, we noted on this blog how the "net neutrality" debate has evolved over time. NCTA has consistently supported our customers’ ability to travel the Internet freely; our Internet access service wouldn’t be of much use without that. But the devil is always in the details and while we have always supported fair rules, it will be critical to move forward carefully.

At a time when our country is developing a National Broadband Plan, it absolutely makes sense to have a single definition of the term “broadband” for regulatory and policy purposes. The FCC announced last month that it was releasing a Public Notice, requesting input on this issue (The FCC’s Carlos Kirjner discussed this in further detail in a blog post) and on Monday, we filed comments in response to this Public Notice.

It’s worth noting that this isn’t the first time the FCC has visited this issue, since the Commission adopted a new definition just last year in connection with changes to the Form 477 broadband reporting process. The 477 process semi-annually collects information from service providers about broadband connections to households and businesses; info has been collected each year, starting with data as of December 31, 1999.  Last year, the Commission found that services with download speeds of more than 768 kbps and upload speeds of more than 200 kbps will be defined as “broadband” services. Such a definition was important for the NTIA and RUS to have for use in their broadband funding programs.

But, as we say in our filing, we don’t think it would be a good idea for the Commission to use the process of defining “broadband” as a vehicle for imposing obligations or setting goals with respect to factors such as speed, price, symmetry or “openness.”  The definition has been, and should continue to be, simply a way to describe what is being made available to customers.  Any discussion of national broadband goals or potential service provider obligations should be done separately.  As cable’s history of providing faster and faster speeds demonstrates, the FCC’s definition has never served as a constraint on what is offered to consumers. What’s needed is a generic definition that focuses on the core functionality of the broadband service that customers are receiving today.

We identify three key advantages to such an approach:

• Using the definitions already in Form 477 (also used by NTIA in its recent mapping Notice of Funds Availability), will enable the Commission to compare a consistent set of data over time.
• Using those existing definitions will avoid the need to make additional changes to the Form 477 reporting process.
• It’s helpful for government agencies to use a consistent set of definitions.

Consistency is important and if we try to measure aspects at too granular a level, it becomes difficult to achieve such consistency.  For example, some parties have raised concerns about using advertised speeds as the basis for measuring broadband deployment.  In the Notice, the Commission notes that advertised speeds “generally differ from actual rates, are not uniformly measured, and have different constraints over different technologies.”  But simply requiring providers to report “actual” speed won’t lead to more meaningful information because there is no uniformity in how it is measured and there are numerous factors beyond the control of the provider that affect upload and download speeds.  Consequently, in our comments, we encouraged the Commission to work with the Internet engineering community to develop a consistent, uniform, reliable method of measuring “actual” speed before making a change.

There are proponents who argue that symmetry should be required, but most broadband networks are engineered to provide higher speeds for downloading than for uploading. Such an approach is based on consumer preferences and behavior; if symmetrical services are required, that would prevent providers from offering asymmetric services that might better suit the needs of some consumers.

A comparison might be made to creating a definition of a “computer.” Such devices can range from a netbook costing a couple hundred dollars to several thousand for a Mac Pro. The core functionality of various computers is what remains the same. Such a straightforward approach is also best when attempting to define broadband, as it exists at this time.