Hello, 
Net neutrality is an important part of having a robust and affordable telecommunication service for all Americans. I support net neutrality and vehemently oppose the FCC’s proposed return to the “light-touch” regulatory framework as proposed in the “Restoring Internet Freedom” rule. The effects of the FCC’s proposed changes would lead to higher prices for consumers, less consumer rights, and increased legal uncertainty based on arbitrary and capricious decision-making. 

First of all in section #26 the definition of telecommunication is fundamentally flawed. Even Title II services today would no longer fall within that definition due to improvements and changes in technology. Today phone landlines make use of routing, switching, compression, and encoding which alters the nature of the original transmission. Therefor even defined title II services in their current form do not meet the FCC’s definition of telecommunications.

Also in section #27 the ISP only “offer” a capability if that capability for example, social media, is provided from within the ISP. A majority of the time an ISP provides access to a capability, or conversely restricts access from a capability. An ISP cannot offer connecting with your friends on Facebook since it does not own Facebook. It provides access to a user that then leverages Facebook’s capabilities to engage with their friends. Furthermore you should assess this from the perspective of the user since an individual consumer is the party with the least leverage; especially if the consumer lives in a rural area with limited ISPs.

In section #33 the FCC states that Title II appears to be a poor fit for broadband Internet access service. This is incorrect. Title II is an excellent fit even if not all provisions and functions of Title II are applicable or useful. Title II is a well-litigated legal structure that provides what is essentially an ala carte menu of regulatory options. The analysis that it is a poor fit simply because not everything was used would, by its logical extension, mean that broad regulatory structures would always be poor fits. 

In section #37 the Commission’s findings that DNS and caching functions incidental is wholly flawed. DNS is integral to the proper function of the Internet and affects consumers, ISPs, and 3rd party providers. DNS translates the human-readable addressing (e.g. https://google.com) into machine-readable reference points (IP addresses). Without DNS we have no functional Internet since it is impossible for consumers to discover, remember, store, and reference all the IP addresses for all the sites they wish to visit. Therefor the adjunct-to-basis exception is an incorrect categorization.

I do not agree with section #73. The Internet conduct standard allows the FCC to prevent ISPs from using their market and physical positions to leverage their own services while degrading competing services. Also the Internet conduct standard can be used to prevent ISPs from degrading services during times of contract negotiation. The tactic has been previously used by ISPs to the detriment of consumers across the USA (ref. https://technical.ly/philly/2014/05/09/graph-shows-netflix-speeds-changed-comcast-deal-comcast-roundup/). In addition the conduct standard prohibits ISPs from manipulating user traffic as seen in when Comcast blocked Peer-to-peer networks (ref. http://www.pcmag.com/article2/0,2817,2217866,00.asp). The aforementioned examples are just a small subset of the problems consumers face when ISPs are lightly regulated and in contradiction to section #74 they are not theoretical problems. Consequently a tough but flexible structure like the Internet conduct standard is necessary to protect consumers from increasing costs.

I do not agree with section #75. In section #75 the FCC declares that it wants to move from a conduct standard that contains a “list of factors that guide the application of the rule” (ref. Section #73) to “commercially unreasonable practices”. Since commercially reasonable and commercially unreasonable incapable of precise definition (ref. https://definitions.uslegal.com/c/commercially-reasonable-efforts/) the FCC is proposing moving to a system that will add legal uncertainty and cost to both businesses and consumers.

In section #80 there is a strong need for a codified No-blocking rule by the simple fact that adherence to the principle of no-blocking is completely voluntary on the part of ISPs and can be changed at any time without notice to the consumer. Since most ISPs are publicly traded companies and are responsible to their shareholders; if the ISP decides that it would be profitable, or even merely convenient, to block certain websites or protocols then there would be little recourse for the FCC and consumers. Such blocking of sites and information is in opposition to the principle of freedom of speech that is a founding principle of this nation. Additionally, the lack of a codified no-blocking rule would give empower ISPs unprecedented leverage in contract negotiations with Internet-based businesses leading to distortions of the market and higher costs passed on to businesses and consumers.

In summary, I oppose the “Restoring Internet Freedom” rule and support strengthening net neutrality.