But we are starting to see a very disturbing meme spread by some folks who think that the government should disrupt this success and inject rate regulation and price control over broadband networks. One such fierce advocate is Susan Crawford, a smart and respected former Obama Administration official who now is a law professor and commentator on broadband policy issues. Crawford took to the opinion page of last weekend’s New York Times to lay out her rationale, but it’s one that we find full of faulty analysis, leading to a disastrous prescription.

In a blog post titled, “Susan Crawford’s Broadband Blinkers“, Richard Bennett of the Information Technology and Innovation Foundation provides a thoughtful and important rebuttal that shouldn’t be missed. Here’s a sample:

Crawford’s particular style of analysis is heavy on vague generalizations and light on substance. She talks about “high-speed connections” without ever specifying a rate, and refers to a number of common applications – such as filling out job applications on-line – as if they required massively reengineered networks when they clearly don’t.

Both columns are worth reading to understand where this debate is going, but let’s make sure that we have a firm understanding of the facts before we rush to conclusions that could devastate one of America’s few thriving industries.

But what about the one-third of American households that hasn’t yet adopted broadband at home?  Research from the Federal Communications Commission (FCC), the Pew Internet Research Center, and other groups shows there’s no single reason why people don’t sign up.  It might be a lack of digital literacy, little or no understanding of the relevance of broadband service, no computer at home, or affordability.

That’s why a new public-private partnership announced recently by cable’s leading broadband providers and the FCC seems so important.  The “Connect to Compete” (C2C) program unites a number of non-profit and private partners in a coordinated, community-based program that is dedicated to a common purpose – promoting adoption among certain families with school-age children that have not yet hooked up to broadband.

Cable broadband providers reaching 86 percent of U.S. households with broadband service have committed to participate in C2C or some other complementary program. They’ll offer a discounted promotional rate of no more than $9.95 a month (plus tax) for high-speed Internet access to qualifying families with kids in grades Kindergarten through 12 who receive free lunch under the National School Lunch Program.  Participating companies will waive installation fees in the case of standard or self-installation.  They’ll throw in a cable modem free of charge during the length of the program, or offer to sell one for a deeply discounted fee.  And those who sign up for the program will enjoy, at a minimum, download speeds of up to 1 Mbps, while some may receive faster speeds.

The program will launch in 2012, in the back-to-school period for the 2012-13 school year.  There will be a sign-up window of three years.  And any family that qualifies and signs up can stay in the program for up to two years.

C2C is the latest step in cable’s long journey of commitment to education.  That commitment to the value of broadband in education actually began more than 20 years ago when we started to wire and connect tens of thousands of schools and libraries, first for cable TV, and then to the information superhighway we now call the Internet.  Our efforts continue today, led by the industry’s non-profit education foundation, Cable in the Classroom, to promote and distribute educational content and help teachers and students use broadband technology and services safely and responsibly.

The program is also part of our legacy to promote broadband adoption.  We’re fiercely proud of being the first industry to bring broadband to American homes. Today, our companies provide broadband service to more than 45 million American homes.  We’re convinced that C2C will enable even more homes to adopt broadband – providing tremendous educational benefit to more American families.

For that reason, we applaud FCC Chairman Julius Genachowski’s announcement today of a new group called Connect to Compete, a “digital literacy corps” which will actively engage with consumers so they understand how high-speed Internet will enable them to find jobs, increase their skills and open up new opportunities.

We’ve addressed the issue of broadband adoption before (“Bringing Broadband to Low-Income Families” and “Increasing Broadband Adoption”), making this point that pertinence, and not just cost, has repeatedly been identified as a significant barrier to broadband adoption. In other words, as we said in this post:

…we’ve seen firsthand that some consumers simply see no benefit in broadband…that is until they start using the service and then they can’t stop.

The cable industry has been a leader in developing public-private partnerships as an avenue to increase broadband adoption. Many cable companies are deeply involved in community-based programs designed to overcome barriers to adoption, improve accessibility to broadband services and provide training and education on digital and internet literacy.

Comcast, Time Warner Cable, Cox Communications, Charter, Cablevision Systems, and Bright House Networks are just some of the cable operators that have launched community-based broadband adoption initiatives. (You can see more details on these efforts here, here and here.)

In addition, Discovery, one of cable’s premier programming companies, will contribute premiere educational content from Discovery Education, including video clips and digital lessons, to help bolster student achievement.

Cable has been a pioneer in proposing national partnerships, including the Adoption Plus program a few years ago, which included many elements that have been embraced in the FCC’s new initiative.

In addition, through Cable in the Classroom, the cable industry provides a variety of tools and resources to educators to encourage broadband adoption and enhance digital citizenship among the nation’s youth.

We’ll be continuing our efforts to encourage adoption and will also continue to engage in discussions with government policymakers and private sector partners to identify new ideas that will substantially advance our common goals.

The Chairman highlighted the economic force that broadband has become in the American economy, especially as a technology that powers job creation, and he cited a recent report by McKinsey which shows that broadband now creates 2.6 jobs for every one lost.

As cable was America’s first broadband provider, I welcome the Chairman’s remarks and enthusiasm about how broadband is sparking a renaissance in America’s economy.  But the irony of the entire speech is that not a single broadband company was even mentioned nor did we hear about the millions of jobs created by broadband providers which have built the networks that are the “indispensible infrastructure for America in the 21st Century.”

Sure, it’s to more fun talk about garage start-ups or cake delivery success stories, but let’s not forget who brought us to the dance.  Broadband is not some mystical force of nature. Broadband is the result of hard work and private investment, first from the cable industry and now many others.

The cable industry launched residential broadband service in the late 1990s and after $170 billion in construction and network upgrades, our broadband service is available to 93 percent of U.S. households – more than 123 million homes.  Cable’s broadband networks offer speeds of 5 Mbps or faster to more than 90 percent of U.S. households. Cable is also now providing next-generation wideband service, with speeds of 50 Mbps or more (in some cases, over 100 Mbps) to more than 90 million American homes.

Currently, 45 million customers rely on cable for their broadband Internet connections. As Chairman Genachowski notes, those broadband connections have become indispensible.

I know it’s been 15 years, but it’s important to remember that it was cable that brought broadband to life and gave birth to everything we delight in today.

But we also help impact the economy. Just this past March, we released the latest study by Bortz Media and Sports Group, Inc. on the economic impact of the cable industry. The study found that the U.S. cable industry supports nearly 1.8 million jobs representing gross economic output amounting to more than $251 billion.

Since 2002, direct and indirect employment attributable to the cable industry has increased by 638,000 jobs.  The industry added 4,700 jobs over the last three years at a time when the U.S. economy’s net loss of jobs was more than seven million.

We deployed broadband first; we offer some of the fastest speeds in the marketplace; we help keep American employed. When you think of the economic impact of broadband, don’t forget the critical role that cable has played.

Now, a new study, which NCTA commissioned and which was prepared by Jeffrey Eisenach of Navigant Economics, shows that flaws in RUS lending practices have extended into the similarly inefficient high-cost Universal Service Fund (USF), creating a double whammy for both taxpayers and companies that are trying to compete against these heavily government-subsidized operations.

Before jumping into the results of the new study, it’s important to state emphatically that the cable industry is absolutely committed to ensuring that Americans have access to telephone and broadband Internet service – goals that we have been working on for decades. While government funding may be necessary to ensure that these goals are achieved in some high-cost areas, the current systems of providing this funding are in need of serious reforms.

First and foremost, resources ought to be devoted specifically to extending broadband access to unserved areas.  Government funding programs, like USF, should be used to provide funding for the building of networks where it doesn’t make sense for private investment.

We’ve previously discussed the critical changes that need to be made to government funding programs. For examples, see this 2009 post on broadband stimulus funding or this 2010 post on how to connect America to broadband in an affordable fashion. In February of this year, we talked about the necessary principles to consider for USF reform. Just last week, we argued that USF funds must be spent in an efficient manner.

The key points of the Navigant Economics study released today can be deduced from its title: The Rural Utilities Service Should Reassess Its Reliance on Universal Service High-Cost Support to Leverage Broadband Loans. To cite a few examples from the document:

• Inefficiencies in the two programs have created a vicious cycle in which consumers finance both the RUS loan and the universal service revenues that underwrite the loan, and where the burdens keep expanding as new RUS borrowings leverage higher USF payments from the high-cost fund, which in turn are used again to justify even more RUS lending.
• Despite the fact that fundamental USF reform – which would reduce the level of USF support received by RUS borrowers – has been on the table for 15 years, and is well-known to be a top priority of the current Federal Communications Commission, the RUS has continued to treat USF subsidies as a stable source of revenue for repayment for loans with maturities of 20 years, an assumption that is highly questionable and seems unrealistic under the circumstances.

The study recommends that RUS should temporarily suspend new loans to recipients of USF funds and stop leveraging USF support to qualify applicants for RUS loans. It also suggests that after the FCC concludes its USF reform proceeding and new rules are in place, Congress and RUS can reassess whether a loan program continues to be needed and if so, how that program can be better coordinated with the USF program to eliminate the problems inherent in the current RUS regime.

The time for reform is here, but let’s make sure we do it right and don’t let past traditions guide future mistakes.

Over the past 15 years, cable has invested more than $170 billion to upgrade networks, add new equipment and improve next-generation networks.  From this significant investment, consumers are reaping the benefits of the fastest speeds to connect with family, telecommute or download an HD movie for their next trip.

But cable is not stopping here.  Operators are continuing to invest and deploy the latest technology for even faster speeds to even more homes.  As we said in an earlier post, Comcast announced in April that it is offering 105 Mbps service to 40 million homes.  At year-end 2010, speeds of 50 Mbps or faster were available to more than 80 million homes by cable operators.  SNL Kagan notes that ultra-fast wideband service – with speed tiers that exceed 100 Mbps – should reach 94 million homes by the end of 2011.

Most importantly, cable’s customers are pleased with these faster speeds and reliable networks.  A June 2010 FCC survey showed that 91 percent of subscribers are satisfied with the speed of their broadband service.

Based on a rigorous testing process, the Commission found that, on average, during peak periods (7:00 – 11:00 p.m. local time), cable-based services delivered 93 percent of advertised download speeds and 108 percent of advertised upload speeds.  When off-peak performance is included as well, many of the cable operators in the test delivered more than 100 percent of the advertised download speed and the majority delivered more than 100 percent of advertised upload speeds.  To the extent the National Broadband Plan suggested there might be a significant gap between actual and advertised speeds, the report dispels those concerns and makes clear that “actual download speeds are substantially closer to advertised speeds” than was asserted previously.

The positive results reported by the Commission reflect the cable industry’s long track record of network investment and innovation and our focus on providing services that are attractive to consumers.  As with Commission surveys showing extremely high consumer satisfaction levels, the results of the SamKnows testing confirm that marketplace forces are working for the benefit of consumers.

The testing also demonstrates the significant consumer benefits associated with PowerBoost technology, which is used by many cable operators.  PowerBoost enables consumers to receive bursts of additional throughput when there is excess capacity in the network.  As the Commission’s report demonstrates, PowerBoost increased download performance by as much as 52 percent during peak periods for some offerings.

Beyond the substantive importance of the results, the SamKnows testing is equally important for the procedural lessons it teaches.  The Commission faced a challenging task in developing a testing mechanism that could accurately measure the performance of different types of ISP networks.   To the Commission’s credit, it recognized that the best way to develop such a process would be to work in a collaborative manner with the ISPs whose networks were being tested, as well as academics, equipment manufacturers, consumer groups and others.  We appreciate the hard work and dedication of the Commission staff throughout this process.

It is important to keep today’s report in perspective.  The test involved only a small fraction of the ISPs operating in the United States (and only covered wireline providers), each ISP had only a small number of test panelists, and the report covers only one month of performance data.  Further analysis of the data is needed to ensure that the testing process fairly and accurately measured the performance of each ISP.   We look forward to reviewing the report in more detail and continuing to work with the Commission staff and other interested parties on these issues.

According to Kornbluh and Weitzner, the Internet is such a powerful engine of economic and social advancement because no centralized authority governs it and no nation owns it – which “means that nations that choose to take a heavy-handed approach to regulating the Internet can reduce its value for every other nation and user.”

In particular, Kornbluh and Weitzner argue that “[t]he first threat is posed by some governments and international institutions intent on imposing pre-Internet-era telecommunications regulatory schemes to provide them control over the flow of information (and money) they enjoyed in the old days of the monopoly phone company.”

We couldn’t agree more.  In this country, the FCC opened a docket to examine whether broadband Internet access service should be reclassified as a pre-Internet-era common carrier service under Title II of the Communications Act.  NCTA and others pointed out that imposing a top-down Depression-era regulatory structure on modern broadband facilities would not only be unlawful but would depress broadband investment and job-producing economic growth at the worst possible time.

Fortunately, the FCC declined to reclassify broadband Internet access service in its Open Internet Order.  Unfortunately, the reclassification docket was expressly left open.

If we want other nations to reject the idea of imposing old-style regulatory structures on the Internet, there’s no place to start like home.  It’s time for the FCC to close the Title II reclassification docket.  That would prevent a future Commission from turning back the clock, and send a clear message to the rest of the world.

It is not an exhibit itself. Nor is it a set of panels. It is a series of nine one-hour talk shows that will be streamed live over the web and that attendees can witness in person.

The conversation in The Park will center on the dynamic changes that the cable industry is going through, which are transforming the customer experience.

For its first 50 years, the cable industry was primarily about delivering traditional television. Since the commercial launch of cable modems 15 years ago, the focus has gradually been shifting to broadband; we have now reached a point where broadband is an enabling platform for a variety of services and is re-defining the traditional media business.

In previous phases of our industry’s history, cable had a particular infrastructure and utilized certain technologies, which then enabled a set of services it could deliver to customers. The Park will show, through practical demonstrations and thought-provoking discussions, that we are now entering a new phase, in which our business operates in a different way, delivering new types of services to our customers.

This is a new world in which Consumer Electronics, Information Technology and Hollywood have become intertwined. At a time when some critics have accused the cable industry of being an obsolete dinosaur, doomed to distinction, the industry is actually turning into a dynamo, becoming a part of the broader ecosystem and finding innovative ways to carry our hybrid fiber-coaxial infrastructure into the future.

Here is the list of the topics we’ll be addressing in The Park over the three days:

• Socially Acceptable: Community Engagement in a Socially-Driven Interactive World. We’ll examine the enormous impact of social media, especially in the areas of customer service, politics and commerce.
• Unplugged: The Mobile Extension of Cable’s Value Proposition. Cable’s broadband services (both video & Internet) are becoming unchained from the set-top box and the modem, allowing consumers to extend the value of their subscription to mobile devices and even outside the home.
• Ideas in Action: Partnerships That Drive Broadband Adoption in America. With the increasingly critical role that broadband plays as a driver of economic recovery, job creation and global competitiveness, how are cable operators helping to drive broadband adoption? Also, a presentation of Cisco’s annual Visual Networking Index will document the growth and use of IP networks worldwide.
• Consumer Voices: Digital Natives – Habits and Habitats of the Next Generation. A special focus group of real consumers will feature tomorrow’s consumers. We’ll be able to learn firsthand from young consumers their experiences, practices, expectations about use of digital platforms in their daily lives and behaviors – today and tomorrow.
• Cable Bridge: You CAN Get There From Here. Cable’s shift to new platforms is still evolving, so we’ll examine the growing momentum towards multi-platform delivery.
• TV Everywhere: The Latest in Cable’s Anytime, Anywhere App-Focused Attitude. Programmers are undergoing radical shifts in their business as well, while still partnering with cable operators. New apps empower authorized subscribers to access shows & movies in a convenient, personalized and portable manner.
• Consumer Voices: New Advertising Strategies & What Consumers will Find Helpful (or Not). Advertising will be key to generating revenue in this new environment. This focus group will look at how consumers will view new ad strategies implemented on diverse platforms including product placement.
• Network Nirvana: Achieving Harmony in Cable’s Connected Home. As broadband converges everything, distinctions between cable’s voice, video and data services begin to fade. Cable’s connected home  allows content to be streamed to any device in the home, and leverages the network to enable new services like home monitoring, automation and security.
• Problem Solvers: Innovating for the Greater Good. Advanced technology is not only a commercial venture, but also a power force for good, affecting everything from educations to civics. In addition, we’ll also discuss cable’s role in advancing the critical IPv6 transition that will make the Internet continue to function properly.

Tune in Tuesday afternoon (June 14) at live.thecableshow.com beginning at 12:30 p.m. (CT) to see the conversation. The whole schedule is online at The Cable Show website.

According to initial feedback, there appeared to be some intermittent software issues, but overall this 24-hour test was a success for those websites participating in World IPv6 Day (See ISOC’s release). It will take some time for Internet companies (websites, ISPs and others) to collect and examine their data, so it will likely be days or weeks before the results are fully analyzed.

As I indicated earlier this week, the cable industry was fully engaged in World IPv6 Day, as befitting our role as leading broadband providers in America. CableLabs, the industry’s research & development organization, kept an open communications line for 26 hours, in order to allow for quick MSO discussion and response to any issues that might have arisen.

We will continue to be involved in this and other key Internet issues (e.g., our sponsorship of the 85th meeting of the Internet Engineering Task Force next year).

Kudos to the Internet Society for taking the lead on this initiative, and for their role to help promote the transition to IPv6.