Dear FCC Staff:

Weakening net neutrality regulations would be a dangerous measure which would
decrease technical innovation, tilt economic opportunities in favor of large
and financially rich organizations, effectively censor certain kinds of content,
and eventually increase costs to to non-institutional Internet and broadband users.
Consequently, it is essential that Internet and broadband service continue to
be classified as a telecommunications service.

Regulating the Internet, and related broadband services, as a public utility under
the telecommunications service framework, is reasonable, has provided fairly good
quality of service for the vast majority of users, provided fair access to economic
opportunity to small organizations and individuals, and generally prevented
interference in the dissemination of information based on its content.

It is important to realize that Internet and broadband access are not the same as
access to entertainment media, such as digital television, or voice services
which are often mislabeled as such. Lack of high speed video service and the like
does not inhibit the most important kinds of Internet and broadband usage, which are
information access and communication, or the operation of most common applications.

While freedom of speech principles prevent Internet and broadband providers from
outright censoring content, the do not prevent providers from disseminating
information they perceive as beneficial to themselves or their associates in
a preferential way. It is far more efficient and less costly to prevent such
abuses with regulation that through legal proceedings.

Allowing different tiers of service on the open Internet will not guarantee
that time sensitive applications, such as a real time medical scan, will receive
the quality of service they need to function reliably. That kind of reliability
requires very low latency and variation of data transmissions rates. Satisfying
the needs of time sensitive network applications requires the use of leased lines
because the high volume of data and unpredictable network segment load on the open
Internet make providing those data transmission characteristics impossible.

Poor quality of service due to infrastructure deficiencies is virtually non-existent.
Instead, poor service is generally due to the "last mile" problem, which is lack of
good connectivity between the network periphery and residences. A public utilities
approach to tasks, such as providing fiber optics lines to residences, is the most
cost effective approach, and perhaps, the only viable approach in rural areas. It
distributes the cost of installing physical plant in an equitable way and insures
access to quality Internet and broadband access are not restricted by income
strata. Internet and broadband in South Korea is an example of a case where
a similar approach has been very successful.

Cordially,


Paul Romero