Dear Chairman Pai and Commissioners of the FCC,

I write to express my opposition to the proposed measure offering looser standards of broadband internet.

In my own past, as a sometimes-needy college student I often went without reliable internet. My experience with mobile internet providers in central Texas near Austin was a frustrating one which would have totally derailed plans that I had for ambitious use of the internet, and web technology, had I not been able to use university networks as a backup. I reiterate, this experience was inside an urban center. Slower speeds and less reliability are problems compounded massively in rural areas. I can think of no more effective way for the FCC to strengthen the digital divide than by backsliding on the requirements of internet speed and accessibility for the sake of telecommunications companies.

I want to invoke the example of the Bell System and its regulation, beginning with the early 20th century and going onward to the 1980s. The US government perceived that a "natural" monopoly in the form of the Bell System (represented today by a very small number of telcos) would inherently pursue the short-term profits of investing capital only in large cities, even in only affluent areas of those cities, where distances were shorter and less wire and fewer switching stations were needed. At best, the poor in rural and tribal areas would receive substandard technology and less reliable or feature-ful access to telephone service. At worst, the phone companies could choose not to even serve communities.

The US perceived this was a threat to the culture and character of its people and their communities. It took the step of requiring the Bell network of companies to serve customers in their geographical areas and regulating quality of service. This was a measure that greatly assisted the survival of smaller American communities and the ongoing participation of millions of Americans in the modern world of business, education, and other fields. 

Reliable access was the basic goal. Imagine how badly off the nation would be if millions of its people still lacked phone service by the middle of the 20th century. Or if it was slow to connect, and of so poor quality that phone conversations were sometimes impossible. Imagine if the law said that the local Bell company was allowed to simply create an ad hoc network of vans with wireless telephone transmitters to supplant the broken system rather than repairing and making it affordable. The comparison is similar; the nation requires individual reliable internet to develop productive citizens, students, businesspeople, scientists, and workers.

Today, it is not merely about reliability, but speed as well. In a world where the technological early adapters drive the pace of the web, websites are very bulky to load and video is all over the internet. 10 Mbps is barely adequate for an individual with ordinary needs, and wholly inadequate for a working family where parents use the internet for applying for jobs and managing their accounts, where children need to use the internet for homework, and where most of the learning content on the web is in video form. 10 Mbps is inadequate for running a home business that needs to react quickly. 25 Mbps, while not perfect, is a much more sensible standard- and it should be going up, not down!

This will not preclude innovation, but will in fact stimulate it. With all of the regulation that the old AT&T Corporation faced as a telephone monopoly, it did not fail to develop new technology or stay competitive. Bell Laboratories, acting as AT&T's research arm, invented the transistor and was host to many Nobel Prize laureates. AT&T developed Telstar, the first communications satellite. It was a wealthy and powerful company, yet it existed with stronger restrictions on its actions than today's corporations. Verizon can innovate just as well while it is obliged to provide a higher standard of service to its customers.

The choice is similar now to what it was then. If we loosen standards and make the process for neglecting less profitable markets easier, we simply make more short-term profit available to a natural monopoly, with no corresponding benefit to the American people or to the state of the art in technology. No plausible positive outcome has even been proposed by the spokespersons of the FCC. Making the standard more lax simply seems, to this citizen, as a handout to massively powerful companies like Verizon, AT&T, Comcast, and Time Warner.

I urge you to not take any measures to weaken the current FCC standard of broadband.

Cordially,
Joseph Moorman