Looks like Verizon was a bit stung by some of the commentary it has gotten in response to a filing it sent the Federal Communications Commission this week. The wireless giant is "OK with low bar when defining broadband," ran a headline on Wednesday in Broadband/DSL Reports. "ISPs, who don't want their network shortcomings highlighted, want the bar rather low," noted the story. "While yesterday we mentioned that the cable industry thinks 768kbps/200kbps is just peachy as a definition, AT&T and Verizon are also just fine with a very low bar."

This observation drew the ire of David Young, Verizon Vice President for Regulatory Affairs. "There seems to be some confusion," around this issue he wrote on Verizon's policy blog this morning, linking to the DSL Reports piece. "The implication here is that we want to keep the speed set low so we won't have to upgrade our networks."

"From where we stand," Young added, "this is clearly absurd."

Aggressive goals

Actually, DSL Reports didn't spell that out in the post, but obviously the implication is what's on Verizon's mind. The company was answering the FCC's call for comments on a definition of broadband. The agency suggests just understanding it based on advertised speeds obscures the fact that ISP performance often falls short of that, due to a variety of factors: logistics, traffic loading, jitter, and other problems. And the FCC wants to know if it should take an "application based approach" to the definition question—in other words, should we associate a tag for broadband with the ability to use certain devices and features?

As Young's defense points out, Verizon started out the filing by urging the FCC to establish "aggressive, long-term targets" that could be revised from time to time to take technological and consumer use change into account. "For example, setting a broad objective of moving toward a downstream target of 50Mbps for fixed services and 5Mbps for mobile services would be an aggressive longer term goal, recognizing that as the marketplace continues to develop there will continue to be variability in the levels of service available in particular areas for the foreseeable future based on a range of technological, geographic, economic and other factors."

And the blog post notes that Verizon is offering some very high-speed services these days: fiber to the home at 50Mbps down and 20Mbps up in some areas. But, as for a definition of broadband now, the filing says it wants the FCC to maintain a "straightforward baseline definition of broadband based on advertised speed"—specifically, "advertised speeds of at least 768 kbps downstream and 200 kbps upstream."

Why? First: "There is substantial value in maintaining a threshold that will enable the Commission to identify a baseline of areas where first-generation broadband services are available," the company suggests. Second: these numbers would offer the Commission and policymakers a "full and meaningful view of the broadband marketplace generally." They are, after all, what the Departments of Agriculture and Commerce are using in considering applications for broadband stimulus money. And finally, "one of the significant benefits of this approach is its simplicity, making it relatively easy for policymakers and the public to understand and work with."

You could, of course, argue that the problem with 768/200 is that the pace of consumer demand for video and audio on the Internet may soon make it irrelevant as a real metric for understanding broadband adoption. But like AT&T and Comcast, Verizon also told the FCC that it doesn't like this "application based approach" business.

"Given the variation, and continued evolution, in applications, the Commission should not define broadband strictly by reference to the requirements of applications," Verizon writes. In fact, the Commission should urge app developers to "fully and clearly to disclose to consumers the foreseeable effects of their applications on a subscriber’s broadband service, on the consumers’ devices or other applications, on the broadband network, and on other broadband subscribers. Such information would facilitate informed consumer choice."

Evolving over time

The big telcos are obviously feeling just a bit tender about all this definitional stuff. AT&T sent Ars a comment on our last story on this proceeding. In it, we noted that the company suggested that the FCC define the "minimal set of applications" that Americans need to be integrated into the Internet economy. "For residential customers, that minimal set of applications should include the ability to exchange e-mails, participate in instant messaging, and engage in basic Web-browsing," AT&T recommended. "It also should include the ability to engage in Internet-based education programs, interact with Internet-based government services, and participate in online energy, healthcare, and public-safety programs."

An AT&T spokesperson explained to us that the company understands that "essential applications will, of course, evolve and expand over time to include things such as real-time video." And the telco's filing did acknowledge that, to a point.

"Higher speeds may, in fact, become a basic necessity; the way we conduct business and run our economy may become more dependent on real-time video or VoIP," it noted. "That future evolution should not stand in the way of unserved or underserved Americans getting what they need today, however. Here, the Commission should define broadband in a way that facilitates achievement and evaluation of immediate progress towards universal connectivity." (Those italics are AT&T's.)

The question, of course, is who gets to define what kind of "immediate" broadband services Americans need "today"? Verizon? AT&T? The FCC? You? This definitional proceeding closes after Tuesday, September 8. You can upload comments to the FCC here (the docket number for field 1, "proceeding," is 09-51).