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Broadband Policy

The FCC Wants to Redefine Broadband Again — 100/20 Mbps This Time

DSLBroadband StaffJune 8, 20236 min read

The FCC under Chairwoman Jessica Rosenworcel has proposed raising the official definition of broadband from 25/3 Mbps (25 download, 3 upload) to 100/20 Mbps. ISPs are predictably furious. Consumer advocates are predictably pleased. And most Americans are probably wondering why this matters at all.

Let me explain why a number on a regulatory definition document is one of the most consequential broadband policy decisions in years.

What the Definition Actually Does

The FCC's broadband definition isn't just a marketing term. It's the threshold the agency uses to determine which Americans have "advanced telecommunications capability" — and consequently, which areas qualify for federal broadband funding programs, which areas count as "served" or "unserved" in coverage statistics, and which communities are eligible for various subsidies and grants.

When Tom Wheeler's FCC raised the definition from 4/1 Mbps to 25/3 Mbps in 2015, the result was a massive jump in the number of Americans officially classified as lacking broadband access. Areas that had been served by slow DSL suddenly counted as unserved. Federal funding priorities shifted accordingly.

The same dynamic will play out if the threshold moves to 100/20 Mbps. Millions of households currently classified as "served" — including most cable customers on basic plans, many fixed wireless subscribers, and essentially everyone on DSL — would suddenly become "underserved." The political and policy implications are enormous.

Why 100/20?

The proposed 100/20 Mbps threshold isn't arbitrary. It reflects the speeds that funding programs like BEAD already require for newly funded buildouts. It also matches the typical bandwidth needed for a household to support multiple simultaneous activities: video streaming, work-from-home video calls, online learning, smart home devices, and gaming.

The asymmetric nature of the proposal — 100 down, 20 up — is a compromise. Consumer advocates wanted symmetric service (100/100), arguing that upload speeds matter more than ever for video conferencing, content creation, and cloud backups. ISPs (especially cable companies) argued for keeping upload requirements low, since DOCSIS cable plant struggles to deliver high upload speeds without expensive node splits and infrastructure upgrades.

The 100/20 split lands closer to what cable can deliver but still pushes well beyond what DSL can achieve. The losers under this definition are clearly the legacy DSL providers and their aging infrastructure.

ISP Opposition

You can probably guess who's opposing this. The cable industry's lobbying arm NCTA, USTelecom (representing telephone companies), and various individual carriers have all filed comments arguing against the 100/20 threshold.

Their arguments fall into several categories:

"It's arbitrary." Industry comments suggest the FCC hasn't sufficiently justified why 100/20 is the right number rather than 50/10 or 75/15. This is technically true and practically irrelevant — every threshold is somewhat arbitrary, and the question is whether 100/20 is reasonable, not whether it's perfectly calibrated.

"It overstates what consumers need." The argument here is that most households don't actually need 100 Mbps for typical use. There's some truth to this — a family of four on Netflix and Zoom can survive on 50 Mbps — but "survive" and "have a good experience" are different things, especially during peak usage when everyone is online simultaneously.

"It will misallocate funding." This is the real concern. If 100/20 becomes the threshold, areas currently classified as served might become eligible for federal broadband subsidies, potentially funding overbuilders to compete with existing ISPs. Cable companies are not wrong to be worried about this — and that's exactly the point from a competition standpoint.

"DSL customers will be left behind." Telco arguments that raising the threshold will essentially write off DSL customers as unserved are correct. They're also not the gotcha the telcos think it is — DSL customers have been left behind by their providers' lack of investment for years. Acknowledging this in the broadband definition is overdue.

Why It Matters for Funding

Here's where the rubber meets the road. The BEAD program distributes its $42.45 billion based on the number of unserved and underserved locations in each state. Currently, "unserved" means lacking 25/3 Mbps and "underserved" means lacking 100/20 Mbps.

If the official broadband definition becomes 100/20 Mbps, the regulatory framework around what counts as "served" effectively shifts. Areas with cable internet at 50/10 Mbps speeds — which are common, especially in older cable plant — would no longer count as broadband-served by the FCC's definition. That changes:

  • Which areas qualify for federal broadband grants in the future
  • How states report progress on broadband deployment
  • Which communities get prioritized for affordability programs
  • How "broadband access" is measured in census data and federal reporting

The new definition wouldn't change BEAD's existing structure (which already uses 100/20 for "underserved" classification), but it would influence the next generation of federal broadband programs, state-level policy, and the overall measurement of America's connectivity progress.

What 25/3 Has Cost Us

The current 25/3 Mbps definition is a relic of 2015 thinking. At the time, it represented a meaningful upgrade over the previous 4/1 Mbps threshold. Eight years later, in a world of 4K streaming, multiple simultaneous video calls per household, and cloud-everything, 25/3 is laughably inadequate.

A household at 25/3 Mbps in 2023:

  • Can stream one 4K video, but not while anyone else is doing anything else online
  • Can hold one Zoom call, with degraded quality if anyone else is streaming
  • Cannot upload large files, cloud backups, or do creative work without painful waits
  • Will struggle with smart home devices, security cameras, and IoT sensors
  • Has zero margin for the next generation of bandwidth-hungry applications

Calling that "broadband" in 2023 is dishonest. It made sense to call it broadband in 2015. It doesn't anymore.

The Bigger Picture

The definition fight is ultimately a fight about expectations. Setting the threshold at 100/20 Mbps tells ISPs, policymakers, and the public that delivering 25/3 service is no longer acceptable, that infrastructure investment needs to keep pace with how people actually use the internet, and that broadband should serve future needs as well as current ones.

The Rosenworcel FCC has been more aggressive on broadband than its recent predecessors. Beyond the definition update, they've also revived data collection on broadband affordability, implemented the new Broadband Data Collection mapping system, and pushed forward on net neutrality reauthorization.

Will the 100/20 definition actually pass? The proposal needs to go through public comment and a final FCC vote. Given the current 3-2 Democratic majority on the commission, approval is likely. ISP lobbying may influence the final number — don't be shocked if it ends up at 100/15 or 100/10 as a compromise — but the trajectory is clear.

The era of calling a 25 Mbps DSL connection "broadband" is ending. Not a moment too soon.

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