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Internet Association Files Net Neutrality Reply Comments With The FCC

Beckerman: “There is simply no reasonable justification for repealing the net neutrality protections currently on the books.”


Washington, DC – Today, Internet Association filed reply comments in the Federal Communications Commission’s (FCC) “Restoring Internet Freedom” Notice of Proposed Rulemaking (NPRM). Internet Association highlighted the overwhelming support for the 2015 Open Internet Order in the comments from a variety of stakeholders.

“Americans overwhelmingly support strong, enforceable net neutrality rules at the FCC,” said Internet Association President & CEO Michael Beckerman. “There is simply no reasonable justification for repealing the net neutrality protections currently on the books. The record fails to show any compelling evidence that the 2015 Open Internet Order has harmed the internet ecosystem, either through reduced investment or some other means.”

Below are key highlights from IA’s filing:

The public record demonstrates broad support from industry, public interest groups, small businesses, and consumers for preserving the existing net neutrality protections. Stakeholders as varied as mom and pop businesses, content creators, state attorneys general, realtors, libraries, universities and educational institutions, healthcare providers, and religious organizations all filed their strong support for the net neutrality protections on the books. From the filing:

“Parties from all parts of the economy and society generally support maintaining the existing open internet rules, and even opponents of the 2015 rules support rules that protect an open internet … Faced with this overwhelming support for open internet rules, the last thing the Commission should be considering is weakening the existing rules.”

Without net neutrality protections, the “virtuous circle” of internet investment becomes a “virtuous semi-circle.” The FCC fails to address how the reversal of the 2015 net neutrality rules would impact investment for internet companies and cloud providers, instead focusing exclusively on how it may have impacted ISPs. From the filing:

“Neither the NPRM nor the comments filed by ISPs address the impact of the 2015 rules on investment in the entire internet ecosystem. As IA and others emphasized in their comments, the existing open internet rules protect a virtuous circle of innovation that benefits the fast-growing, cloud-based economy and, in turn, leads to positive outcomes for the broader U.S. economy as businesses turn to the cloud to more efficiently run their operations….It is as if what was relevant was a ‘virtuous semi-circle of innovation’ in which the only costs and benefits to be considered are those that impact ISPs, rather than the public interest in policies that support innovation and investment across the entire internet ecosystem.”

The public record does not provide support for the FCC to reverse or even revisit existing net neutrality protections. In order to change current protections, the public record would need to show clear evidence – including cost benefit analyses – that these net neutrality rules harm the internet environment. That evidence is not there. From the filing:

“The record does not provide the Commission with ‘good reasons’ to reverse course from its 2015 Order. For the Commission to reverse course barely two years after the 2015 rules went into effect and without reliable evidence of erroneous predictions in the 2015 Order would represent exactly the sort of arbitrary and capricious agency decision-making prohibited by law.”

The FCC should preserve the 2015 OI’s rules and scope, in additional to its authority to protect and preserve the open internet. The 2015 net neutrality protections are working and the FCC is the agency with the expertise and resources necessary to preserve a free and open internet. From the filing:

“Acknowledging the importance of open internet protections to consumers and to the internet ecosystem generally, even opponents of the 2015 rules, including most large ISPs, express support for basic open internet protections including a transparency rule and bright line rules prohibiting blocking and throttling. In addition, at least some major ISPs support prohibitions on most forms of paid prioritization, and are on record in the past forswearing from any form of paid prioritization arrangement. However, numerous commenting parties agree with IA that the Commission should maintain its existing open internet rules and the scope of the 2015 Order.”

To read the full filing, click here.