2015 called. They want their debate about equal access back.
01 May 2017
FCC Chairman Ajit Pai wrote a proposal to roll back net neutrality protections,
misleadingly named “Restoring Internet Freedom.” Its viewpoints
represent a huge step back for competition on the Internet. Here are some choice
quotes from my quick skim (emphasis mine):
Internet service providers routinely change the form or content of the
information sent over their networks — for example, by using firewalls…
We believe that consumers want and pay for these functionalities that go
beyond mere transmission — and that they have come to expect them as part
and parcel of broadband Internet access service.
— Restoring Internet Freedom, Paragraph 30
Sorry, which consumers are asking for more ISP-based features? We just want fast
Netflix, and enough competition to ensure that founders can create more
Netflixes in the future.
When is “throttling” harmful to consumers? Does the no-throttling rule prevent
providers from offering broadband Internet access service with
differentiated prioritization that benefits consumers?
— Restoring Internet Freedom, Paragraph 82
Translated: What is this harmful “throttling” of which you speak? Lobbyists have
paid us not to understand!
I was hoping to submit a few sentences and be done with it, but the more I read,
the more I felt that Someone Was Wrong On The Internet.
Here are my “brief comments” in case they help inspire yours:
I am writing to oppose Docket No. 17-108, a harmful proposal predicated on
misleading views about the nature of the Internet.
Paragraph 29 claims that ISPs don’t offer “telecommunications” services because
the users don’t know which IP addresses they wish to communicate with, and don’t
know where their data is being stored. This explanation is technically correct,
but unfortunately, in focusing on the implementation details rather than
describing how users understand the Internet, it loses the forest for the trees.
For example, the average consumer know the difference between calling their
family over Skype or FaceTime. Although the mechanism through which the user’s
computer directs the ISP to send voice data involves first translating the
domain name to an IP address, that is merely an artifact of history which is
never seen by the typical consumer. The Internet could have been designed so
ISPs handle requests without that translation step. But the behavior and
incentives of ISPs would remain the same from the viewpoint of regulators and
consumers. It’s clear that “points specified by the user” should mean the names
of websites or other service providers — not the physical or IP addresses of the
machines providing the services.
Paragraph 29 also asks what functionalities ISPs serve beyond mere transmission.
As an internet user, my answer is “none.” I am not interested in any additional
services offered by my ISPs, Comcast and AT&T Mobility. I am paying them to
transmit my data to and from the websites of my choice as quickly and cheaply
Paragraph 30 asserts that users would be willing to pay for additional services,
such as ISP-based filtering. As a user, I believe this to be false. I use
Comcast at home, Cogent at work, and AT&T Mobility on my smartphone. What I need
the most is a consistent experience across my ISPs. If AT&T offers filtering but
Comcast does not, then the webpages I visit at home might look different from
the webpages I load on the bus.
Additionally, firewalls do not represent a “change in form” of the content.
Firewalls only block or allow content to pass through the network. A firewall
cannot, for example, summarize a news article like a blogger might, or filter a
pictures as a photographer might.
Paragraphs 72–75 ask about the purpose of the internet conduct standard, and
82–84 ask whether it’s necessary to prohibit throttling and paid
prioritization. When ISPs treat traffic equally, regardless of source or
destination, the Internet becomes a vibrant and competitive marketplace. It’s
why, for the past 20 years, consumers have been able to choose the services they
prefer. It’s allowed businesses, even small ones, to compete for customers on a
level playing field. This situation began to change a few years ago. Comcast
refused to peer with Netflix, causing Netflix movie streams to stop loading
while Comcast’s own media offerings worked flawlessly. Fortunately for Netflix,
they already had deep enough pockets to pay off Comcast. But what happens when
the next startup doesn’t? Even if they have a better product, they will have a
harder time driving adoption because of the increased costs associated with
pay-to-play access. In conclusion, now that ISPs are threatening to throttle
competing service or zero-rate their own offerings, it’s essential for the FCC
to impose standards to ensure that all players have equal access to the network.
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