Why 25/3 Broadband Is Not Sufficient

In the interest of “closing the digital divide,” the FCC issued a Notice of Inquiry in August “Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion.” According to the notice, the FCC still considers it reasonable and timely to define the minimum broadband speed as 25 Megabits per second (Mbps) download and 3 Mbps upload, the same minimum speeds the FCC first established in 2015.

It’s an important benchmark that is widely-agreed to be outdated in the era of families juggling multiple video chat calls and other digital tasks at the same time.

However, according to the FCC’s most recent look at the issue, there remains “significant support for maintaining this benchmark.” Therefore, the notice went on to say, “we propose to maintain the 25/3 Mbps benchmark for fixed services.”

This, despite the objection of Commissioner Jessica Rosenworcel, whose official dissent noted that, in addition to the “nonstop criticism from consumers and Congress” over the FCC’s misleading data on how many Americans lack access to broadband, “in its last report, the FCC continued to use a broadband standard that is too low for a nation that has moved so much online.”

“Many households with multiple users are calling, watching, listening, gaming, and searching online all at the same time,” Rosenworcel noted. “But the FCC has been sticking with a download standard of 25 megabits per second that it adopted more than five years ago. We need to set audacious goals if we want to do big things. With many of our nation’s providers offering gigabit service, it’s time for the FCC to adjust its baseline upward, too. We need to reset it to at least 100 megabits per second.”

A year prior to Rosenworcel’s dissent, Next Century Cities submitted comments noting how much had changed both up and downstream since the 2015 standard was put in place.

“As more people work from home or engage in online education courses, the requirement of multi-tasking while participating on an HD video conference will overwhelm that 3 Mbps capacity, even if no other devices in the household are attempting to share the network.” 

Next Century Cities pointed out how devices like Nest cameras, Ring doorbells, and other security monitoring devices are more common and place greater strains on upstream capacities in ways not anticipated by the FCC’s 2015 basic broadband standard.

Furthermore, Next Century Cities noted an often overlooked ancillary benefit of better connectivity: “homes with robust Internet connections sell faster and at higher prices than homes that lack more advanced access.” 

The New America’s Open Technology Institute’s (OTI) 2020 “Cost of Connectivity” report has also called for a higher threshold (100 Mbps download speed) for broadband, while also expressing support for an even higher standard of 1 gigabits per second (Gbps) download speed.

The OTI report makes the case for why a minimum 100 Mbps standard or higher better reflect users’ needs, citing a Pew Research Center survey conducted in 2016 (just a year after the FCC set the 25/3 standard) that found the typical U.S. household uses five devices, and nearly one-in-five households use at least 10 devices.

“While speeds below 25/3 Mbps may be sufficient for a single device, these households with five or more users or devices require over 25 Mbps for even moderate Internet use,” the OTI report notes.

The minimum federal standard is also important for another reason: to ensure that broadband subsidy programs look far enough into the future so that taxpayer money is not wasted.

Areas believed to have 25/3 service already do not qualify for most broadband subsidy programs, though most agree that the FCC has poor data on whether that level of service definitively exists in any given region. Most broadband subsidy programs require delivering a new service that is at least that fast, although given the trajectory of increased online usage some experts worry that if a subsidized network is merely offering 25/3 in 2020 or later, it is an example of government subsidies building obsolete technology that will not create the educational, economic, or other benefits that should justify the expense. 

By way of analogy, Christopher Mitchell, Community Broadband Networks Director for the Institute for Local Self-Reliance, draws a comparison between building broadband infrastructure and bridge construction: "When we build bridges, they are not built to handle expected traffic just 10 years from now, but to deal with what can be anticipated for decades after that."