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Internet Association Files With FCC And Calls For Net Neutrality Rules To Be Kept In Place

BECKERMAN: “There is zero evidence that the Order has harmed the internet economy. In fact, we have strong evidence showing that ISPs, consumers, and internet companies of all sizes are thriving under the order. Rolling back net neutrality rules would stifle innovation and choice online.”


Washington, DC – Today, Internet Association filed its comments in the Federal Communications Commission’s (FCC) “Restoring Internet Freedom” Notice of Proposed Rulemaking (NPRM). Internet Association offered its full-throated support for the 2015 Open Internet Order.

“The facts are clear: the 2015 Open Internet Order is working and does not need to be changed,” said IA President & CEO Michael Beckerman. “There is zero evidence that the Order has harmed the internet economy. In fact, we have strong evidence showing that ISPs, consumers, and internet companies of all sizes are thriving under the order. Rolling back net neutrality rules would stifle innovation and choice online.”

Below are key highlights from IA’s filing:

  1. Both Quantitative And Qualitative Evidence Demonstrates The 2015 Open Internet Order Is Working. The Entire Internet Sector Is Thriving And There’s No Need To Change The Rules.
    • IA’s filing includes robust, statistically significant economic analysis that demonstrates ISP investment has not declined because of the current net neutrality rules. This quantitative evidence points in the same direction as the ordinary course statements from ISPs themselves since the current rules were enacted.
    • From the filing: “There is no reliable evidence that the 2015 Order has reduced ISPs’ investments in broadband infrastructure. Comprehensive economic research by IA has found that ISP investment is up over time, and shows no decline as a result of the Commission’s 2015 Order…Multiple, independent metrics — from actual capital expenditure numbers, to capacity, to prices — demonstrate that ISP claims of depressed investment don’t mesh with reality.”
  2. Loss Of Net Neutrality Rules – Especially Rules Preventing Paid Prioritization – Would Jeopardize Investment And Innovation Online.
    • In a world without net neutrality protections, startups would face discrimination from ISP owned or preferred content that’s granted a speed advantage through paid prioritization. This would hurt competition and consumer choice.
    • From the filing: “Allowing paid prioritization would in effect result in the ‘cable-ization’ of the Internet, in which edge providers (like creators of video programming in the cable context) would have to negotiate carriage deals on ISP networks in order to reach consumers effectively. This would harm startups and other small edge providers who lack the resources to pursue and pay for prioritized carriage, and would place all edge providers at the mercy of ISPs who would face minimal constraints on their ability to charge edge providers for prioritized access. The ultimate losers would be consumers who would be denied the wide variety of sources of content and services from edge providers.”
  3. The FCC Should Continue To Maintain Light Touch, Legally Sustainable Rules That Protect The Internet Ecosystem.
    • IA calls for the FCC to support light touch, bright line, ex ante net neutrality rules that prohibit blocking, throttling, and paid prioritization; prohibit unreasonable interference or disadvantaging of content by internet service providers (ISPs); apply equally to wireless and wireline internet connections; and include robust transparency requirements.
    • From the filing: “As the Commission has explained previously, ISPs have clear economic incentives to favor their own or affiliated content over third-party, edge provider content. Whether by blocking, throttling, or otherwise discriminating against third-party content, ISPs have the ability to negatively influence their subscribers’ experience with third-party content and use their gatekeeping power to favor their own or affiliated content, thereby limiting consumer choice and competition.
  4. The NPRM Fails To Acknowledge Extensive Investment By Internet Companies In Cloud Services, Which Are A Critical Part Of The “Virtuous Circle” Of Internet Investment.
    • Investment in the cloud by IA member companies is a significant part of the internet ecosystem. Innovation by internet companies fuels consumer demand for ISP services, which in turn incentivizes ISPs to invest more in their networks. These investments must be carefully weighed by the FCC as it moves forward.
    • From the filing: “The NPRM’s failure to address how its proposals will impact the cloud economy represents a fundamental misunderstanding of innovation and investment in the broadband economy and threatens to harm the largest driving force in the U.S. economy today. The success of the cloud economy and the transformation of the Internet into an indispensable part of daily life is largely based on a free and open Internet, one that enables consumers to access any website or app, buy any product, and use any service they choose.”

“Strong, enforceable net neutrality rules mean that consumers, not ISP gatekeepers, decide who wins and loses on the internet. No one wants to live in a world where the internet is like cable TV and consumers have to pay to access only a curated version of the internet,” concluded Beckerman.

In addition to the filing, all of IA’s member companies jointly filed a letter in the NPRM docket in support of net neutrality principles. From the letter:

“IA companies stand united for net neutrality. IA founding companies were built on the internet’s open architecture and best efforts commitment to treat all traffic equally, providing consumers with access to the lawful content of their choosing. Rules of the road are crucial to smaller IA companies as well as start ups along the internet economy’s long tail.”

To read IA’s full filing, click here.

To read the member company letter, click here.

To read the economic analysis mentioned in the filing, click here.

To read a two page summary of the economic analysis, click here.