The California Public Utilities Commission might not offer an opinion on how fast broadband service should be in order to support “advanced telecommunications capability”, but it is on track to say whether mobile and wireline service should be lumped together. According to draft comments that’ll be filed with the Federal Communications Commission if CPUC commissioners concur, the answer is a qualified no…
The CPUC should share its finding that mobile and residential broadband services are “generally not substitutes”, in order to assist the FCC in its consideration of this issue. The object of the CPUC’s investigation was to take a snapshot of the telecommunications marketplace in California, with an “as of” date of December 31, 2015. The CPUC should make clear that this finding was made within that timeframe, as the CPUC continues to measure wireless performance.
The draft also recommends that mobile broadband performance should be actually measured, and not just evaluated on the basis of what the design specs for 4G and 5G technology say ought to be possible…
Finally, the CPUC should urge the FCC to not use interface technologies as a proxy for speed benchmarks. While LTE (or newer generations of mobile technology about to be deployed) is required for mobile service to support advanced capabilities, the CPUC’s mobile data and analysis show that LTE air interface technology often has quality and reliability problems that cause throughput to be highly variable. The sheer number of failed mobile broadband connections experienced in the California, especially in rural areas of California, shows that air interface technology should not be used as a proxy for speed, quality or reliability.
The FCC is conducting its annual evaluation of broadband availability and performance and is considering, among other things, whether the current 25 Mbps download and 3 Mbps upload standard should be lowered, in order to make it easier to declare victory by claiming access to advanced telecoms services is ubiquitous.
The CPUC is scheduled to decide whether or not to bless the draft comments at its meeting on Thursday.