Public Knowledge in Comments to FCC: High Speed Broadband Benchmark is Far Too Low

Public Knowledge filed comments and reply comments urging the Federal Communications Commission to increase its current broadband benchmark speed to at least 100 Mbps downstream based on evidence that American consumers already are using those speeds and many consumers are adopting even higher speeds. Since those comments were filed, more information has been released from the FCC and other third-party sources that support increasing the FCC's broadband benchmark speed from 25/3 Mbps. This letter highlights that additional evidence to support the adoption of a new broadband standard of at least 100 Mbps. 

The FCC under Chairman Ajit Pai’s leadership is considering a number of new broadband policy proposals that emphasize the importance of robust, future-proof broadband networks that will deliver high broadband speeds (up to at least one Gigabit). We support the FCC taking a forward-thinking, modern approach regarding mobile and fixed broadband policy, and we strongly believe that the FCC should take the same approach regarding fixed broadband services by increasing the current benchmark speed. The FCC has not updated its benchmark broadband speed in five years. This is so despite significant increases in the speeds being delivered by broadband providers. We strongly encourage the FCC to increase the benchmark speed in order to portray a more modern, realistic broadband standard to at least 100 Mbps.