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“Restoring Internet Freedom” Notice of Proposed Rulemaking [pdf]

• wickedlogic 9y ago
  Time to build out those mesh networks, make sure you are in the loop when your town wants to grant favor to one or the other of the carriers. Consider this the step... that wont ratchet back anytime soon.
• pdelbarba 9y ago
  Is it normal for these proposals to read like a plagiarized high school report? They repeat "open internet" 43 times (disregarding the fact that the proposal is for quite the opposite) and copy-paste whole sections around the document, over and over again.
  • sinak 9y ago
    It's very much on purpose: the language is carefully crafted to protect the new rules against future lawsuits.
    • pdelbarba 9y ago
      How so? I'm genuinely curious.
      • sinak 9y ago
        Future lawsuit will refer to this NPRM as evidence. As a result, the FCC's lawyers spend a lot of time trying to protect themselves, which means the text of the NPRM is worded in an overly complicated way.
  • idbehold 9y ago
    By "open internet" they mean, "open to becoming monopolized" or "open to the highest bidder".
    • LoonyBalloony 9y ago
      ISPs (at least around where I live) pretty much are already a monopoly. Can you tell me how this is will be worse then our current situation?
      • pdelbarba 9y ago
        The aspect of this that people are mostly taking issue with is the ability for ISPs to try to extort money from hosts and more money from users by throttling traffic if they don't pay. The famous example is when Comcast attempted to force Netflix to pay more for the distribution bandwidth that they use (not the upload bandwidth necessarily, but the load that Netflix was imposing as users downloaded streams). This resulted in Comcast throttling data from netflix servers until some sort of deal was reached. The legislation this proposal would remove protects consumers from this behavior.
      • idbehold 9y ago
        Comcast/NBC will be able to put things like Hulu in the "fast lane" and other services like Netflix will not. Unless of course Netflix is willing to pay Comcast/NBC more. In which case the ISP will be able to charge twice for the same service. The consumer pays the ISP to access the internet, and the service pays the ISP to deliver their content to the user.
      • thomastjeffery 9y ago
        That fact is the basis for the problem. Net neutrality prevents ISPs from abusing their customers. Without net neutrality, the free market must react by creating alternatives. Since these ISPs are essentially monopolies, the free market cannot react.
        • LoonyBalloony 9y ago
          Thanks for the ELI5! :-)
    • jacquesm 9y ago
      Romania is fantastic in this respect. Somehow during the first decade the government didn't take this internet thing all too serious resulting in a decade long free-for-all when it came to internet providers. You can have incredible speeds for very little money there.
  • QuinnyPig 9y ago
    Yeah, this definitely has the feel of "A ten page paper is due, and I've said everything I needed to say in three pages."
  • defined 9y ago
    Although my data is very limited, I am beginning to suspect that quite a bit of new documentation produced by the current administration looks like high school work. As admittedly minuscule evidence, I present the I-130 USCIS (was the INS) PDF form[1], which ballooned from 2 well-designed pages to a hideous 9 page effort, which has amateurish field validation and vast expanses of unfilled boxes into which one cannot even type "N/A" (because it's generally a bad idea to leave blank text fields on important forms) [1]: https://www.uscis.gov/sites/default/files/files/form/i-130.pdf https://www.uscis.gov/sites/default/files/files/form/i-130.p...
• pdonis 9y ago
  Here is a draft of a comment I plan to submit to the FCC regarding this notice: The draft seeks comment on the analysis in Paragraph 27. This analysis purports to show that broadband Internet service is an information service because it provides users the "capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information via telecommunications." The argument given is that broadband Internet service allows users to do all these things. However, this is not the same as providing the capability to do these things. To see why, consider that providing users Internet services over dialup phone lines also allows users to do all these things; but the phone lines themselves are telecommunications services, not information services. Why? Because providing the user dialup Internet, by itself, does not provide them the capability to do all these things. That capability is provided by the endpoints: the users' computers, and the computers hosting the Internet services that the users connect to. Exactly the same is true of broadband Internet services provided by ISPs: by themselves, they do not provide users the capability to do all these things. They only provide connections between computers at the endpoints that provide those capabilities. It is the services provided by the Internet hosts that users connect to that are "information services". The broadband Internet services that allow users to connect to those hosts are telecommunications services, and should be regulated as such. ISPs object to analyses like the one above because they claim that they also provide the actual information services--in other words, they also provide Internet hosts that function as email servers, web servers, etc. But it is obvious that those services are separate from the broadband connection services provided by those same ISPs, because users can make use of the latter without making use of the former at all. I am such a user: I use the broadband Internet connection provided by my ISP, but I do not use any of the information services they provide; I do not use their email, their web hosting, etc. I use other Internet hosts provided by other companies for those services. The fact that ISPs offer information services as well as telecommunications services does not make their telecommunications services into information services; an ISP's choice of business model cannot change the nature of a particular service it provides. Broadband Internet connections are obviously a telecommunications service, and should be regulated as such, regardless of what other services ISPs would like to bundle with them. The FCC should continue to regulate broadband Internet service as a telecommunications service.
  • 9y ago
• vdnkh 9y ago
  >We propose to return jurisdiction over Internet service providers’ privacy practices to the FTC, with its decades of experience and expertise in this area.157 We seek comment on this proposal. Somehow I feel that their "decades of experience and expertise" is not the kind appropriate for dealing with privacy on the modern internet.
• sinak 9y ago
  This is the link for submitting comments: https://www.fcc.gov/ecfs/search/filings?proceedings_name=17-108&sort=date_disseminated,DESC https://www.fcc.gov/ecfs/search/filings?proceedings_name=17-... Just click "New Filing" or "New Express" depending on what kind of comment you want to leave. We just submitted comments here in case you need ideas: https://ecfsapi.fcc.gov/file/DOC-56ec3d08ba000000-A.pdf https://ecfsapi.fcc.gov/file/DOC-56ec3d08ba000000-A.pdf
• Aaron1011 9y ago
  From Page 10: > In contrast, Internet service providers do not appear to offer “telecommunications,” i.e., “the transmission, between or among points specified by the user, of information of the user’s choosing, without change in the form or content of the information as sent and received,” to their users. For one, broadband Internet users do not typically specify the “points” between and among which information is sent online. Instead, routing decisions are based on the architecture of the network, not on consumers’ instructions, and consumers are often unaware of where online content is stored. Domain names must be translated into IP addresses (and there is no one-to-one correspondence between the two). Even IP addresses may not specify where information is transmitted to or from because caching servers store and serve popular information to reduce network loads. This is absurd. Under this logic, telephones "do not offer 'telecommunications'": * Telephone users never specify the 'specify the “points” between and among which information is sent'. When I call a particular phone number, I can't choose which cell towers are used, or what internal routing is used to connect my call. * Users are often unaware of 'where [content] is stored'. When I place a call, I don't know if I'm calling a SIP phone, landline, cell phone, or something else entirely. * If the existence of DNS means that the ISPs don't provide 'telecommunications', then the existence of phone directory services (e.g. Version 411) should mean that telephone companies also don't provide 'telecommunications'. * IP addresses are logical address, not physical addresses. Neither phone numbers nor IP dresses specify exactly where information will end up - a call could be handled by a phone company-provided voicemail service, or redirected to another phone entirely. It gets worse. From the same page: > For another, Internet service providers routinely change the form or content of the information sent over their networks—for example, by using firewalls to block harmful content or using protocol processing to interweave IPv4 networks with IPv6 networks Again, all of those items are analagous (no pun intended) to similar parts of telephone networks. Phone companies can block calls by scammers (e.g. http://fortune.com/2017/03/24/how-t-mobile-plans-to-block-phone-scammers-and-crooks/ http://fortune.com/2017/03/24/how-t-mobile-plans-to-block-ph...), and can change the encoding and encapsulation of the call audio as many times as they want to.
  • pdonis 9y ago
    These are good points; do you mind if I add them to the draft comment I am preparing (which I've posted--in two installments--in this discussion thread)?
• pdonis 9y ago
  Further comment after reading more of the notice: The draft also seeks comment in Paragraph 28 on whether "offering Internet access is precisely what makes the service capable of 'generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information' to consumers?" The answer to this question, as noted above, is no, because all of those capabilities are not provided by the mere fact of Internet access; they are provided by the endpoint computers that implement those capabilities. The question of how those computers are connected to each other is a separate question from the question of what capabilities they provide. Paragraph 28 also asks whether consumers could "access these online services using traditional telecommunications services like telephone service or point-to-point special access?" Obviously the answer to this question will depend on what connectivity the providers of such telecommunications services choose to provide. But that is a different question from the question of what the nature of a particular service is. Paragraph 29 attempts to argue, in effect, that if most Internet users rely on their ISPs for any additional service beyond the bare fact of Internet connectivity--for example, DNS--then broadband Internet service must be an information service. Paragraph 29 also claims that ISPs, not users, "specifies the points between and among which information will be transmitted", because, first, users only specify domain names, not IP addresses, and second, users do not make the routing decisions that determine the specific path information packets take through the network. Neither of these considerations affects the proper classification of broadband Internet service as a telecommunications service. Users might only specify domain names, but the service of translating domain names into IP addresses is provided by an endpoint--a DNS server--somewhere, not by the bare provision of an Internet connection. (And even if the ISP typically provides this endpoint, that is still a separate service from the service of providing an Internet connection, and, as above, bundling the two together cannot change the nature of the latter.) Once the DNS service has provided an IP address to the user's computer, corresponding to a domain name, the user's computer, not the network, specifies that IP address as the target of information packets, so once again, it is an endpoint, not the network itself, that determines where the information goes. And routing information packets, in and of itself, is not an information service, because it does not change the information being routed; it just realizes the information transmission specified by the user, from one endpoint to another. The intermediate routers that pass on information packets are not endpoints. Paragraph 30 attempts to argue that network management activities such as firewalling and IPV4 - IPV6 translation constitute changing the information. This analysis fails in two ways. First, refusing to transmit information (e.g., a firewall blocking content deemed to be harmful) is not changing it. Refusing to provide a connection to a user is not the same as changing the information transmitted by the user. Second, more generally, the "information" which is changed by such activities as IPV4 - IPV6 translation is not the information sent by the user; it is network management information which is added to the information packets specified by the user, outside the user's control and indeed without the knowledge of most users (since most users are not familiar with the technical details of IP networking). These network management activities are no different from the activities routinely performed by phone networks to route calls--indeed, today the same physical infrastructure is often used to perform both functions, since the phone service backbone and the Internet backbone are in many cases the same networks.
• jarcoal 9y ago
  They keep using terms like "Internet Freedom" or "Open Internet", but this isn't so much about the internet as it's about ISPs. They are the gatekeepers of the internet and Net Neutrality requires them to keep the gate open and free of obstacles.
  • clarkmoody 9y ago
    Reminds me of the previous administration always offering "common sense" proposals for everything controversial.
  • smacktoward 9y ago
    In fairness, it does restore the freedom of ISPs to hold you upside down and shake you until money stops falling out of your pockets. So there's that.
    • ddingus 9y ago
      That is, in fact, freedom.
      • ddingus 9y ago
        Meant as sarcasm. I do not favor these changes, just to be clear.
    • mark-r 9y ago
      The perverse part of this is that they're not just shaking you down, they're shaking down the services that you're using. Burning the candle at both ends.
    • arca_vorago 9y ago
      Welcome to GPL vs BSD manifested.
  • hackuser 9y ago
    The title is click-bait and propaganda. Perhaps the HN title should be changed to 'FCC Notice of Proposed Rulemaking on Net Neutrality.'
• JohnJamesRambo 9y ago
  "Restoring Internet Freedom" It reminds me of some Newspeak the government in 1984 would say. Just blatantly saying the opposite of what they are doing like that will make it true. War is Peace Freedom is Slavery Ignorance is Strength
  • Kenji 9y ago
    Freedom as another word for 'regulating to death'. I feel so free in modern society, as the body of law grows day by day, already being a completely incomprehensible mess that no human (or company) can abide by. EDIT: Also, before you downvote, please try to find a fault in the following statement: 'as the body of law grows day by day, already being a completely incomprehensible mess that no human (or company) can abide by.' If you can, please post why. If you cannot, please go back to pondering about this.
    • admax88q 9y ago
      Are the ISPs really being regulated to death?
      • Kenji 9y ago
        Yes. The number of things ISPs have to do is already ridiculous. I.e. data retention, etc. None of this has any benefit for the customers, and it is why growth is hampered.
        • thomastjeffery 9y ago
          > None of this has any benefit for the customers Net neutrality has many benefits for customers. Net neutrality has no detriments for customers. Net neutrality is what we are talking about here. When we conflate "all regulation" with "one regulation", we disregard any meaningful conversation about the "one regulation" with a mess of argument over "all regulation". Please, help us stop doing that. If you want to talk about any of the other regulations, I would love to have a conversation about them. Just be specific, please.
      • 9y ago
• thomastjeffery 9y ago
  > Propose to return authority to the Federal Trade Commission to police the privacy practices of Internet service providers This must have been the promise during S. J. Res 34.
• ShannonAlther 9y ago
  From page 3, on the regulation of ISPs as utilities: ...the order has weakened Americans’ online privacy by stripping the Federal Trade Commission — the nation’s premier consumer protection agency — of its jurisdiction over ISPs’ privacy and data security practices. That's pretty rich, coming from the government that just overturned an Obama-era privacy ruling.
  • overcooked 9y ago
    The claim made in the quotation is also simply inaccurate. As footnote 153 in the NPRM notes, the FTC was already stripped of jurisdiction over ISP privacy practices, regardless of the classification of broadband. (The FTC Act includes an exemption for common carriers based upon their status. Most ISPs are common carriers based upon their other businesses (telephone) and thus exempt.)
• jacquesm 9y ago
  As soon as you see 'Freedom' in some official publication you can bet your last buck that you're losing freedom.
  • bb88 9y ago
    It's not freedom for you, it's freedom for your ISP. According to the law, corporations are people too.
  • ikeyany 9y ago
    Newspeak for sure. Can't speak out against it without being ostracized from the establishment. It worked with the Patriot Act, among countless others, so why would they stop?
  • archgoon 9y ago
    Or someone's about to be bombed.
    • beedogs 9y ago
      With the maniac currently in charge, that's also a possibility for Americans right now.
  • wheelerwj 9y ago
    Freedom or Patriot, are anything but.
• wnevets 9y ago
  Some of the first speech that censored will be by freedom loving ISPs will be hate speech and pro-nazi related speech, a bit ironic
• devindotcom 9y ago
  There's a giveaway in my opinion in the length the NPRM goes to in questioning the necessity of the existing rules, and the small space afforded to providing a legal basis for enforcing them should Title II authority be revoked as proposed. The idea seems to be: if the rules themselves (no throttling, no paid prioritization etc) are not necessary (i.e. voluntary), neither is a legal framework to support them. So statements that net neutrality is not under fire here, only the current legal basis for it, sound pretty hollow in my opinion. By failing to provide an alternative authority to support the existing rules, they're sentencing them to unenforceability and effective repeal. (edit: grammar)
• Sephr 9y ago
  I feel like this belongs here: https://twitter.com/fightfortheftr/status/855144442898132992 https://twitter.com/fightfortheftr/status/855144442898132992 It's a disgustingly disingenuous billboard near the FCC headquarters that is being seen by many FCC employees on their commute to work.
  • outsidetheparty 9y ago
    "Tech-socialists", huh? Do we get t-shirts?
  • ethics_gradient 9y ago
    The idea of tech-socialism is so dumb here, you would think the ad would have an opposite effect...
  • thomastjeffery 9y ago
    I have never wanted to draw graffiti all over a billboard as much as I do this one.
• pasbesoin 9y ago
  I don't think I can put up with 4 more years of these bozos. Since I'm a nice, law-abiding citizen, I can only suggest further unearthing and bringing into the light of day all the sleaze in these people's backgrounds and getting them disqualified and removed from office. The 2008 financial crisis should have ended a lot of sleazy careers. Instead, here we are. There are good people on both the "liberal/progressive/whatever" side of the arbitrary political fence, and on the "small-c-conservative/values/whatever" side. It's the sleaze. On whatever side. Arrogant sleaze. Slime-y sleaze. Delusional sleaze. Psycho-/Socio-pathic sleaze. Time for the War on Sleaze. Only, we don't want war. We want reasonably rational and emotionally mature discussion and the ability to get along and get things done. And enough trust in good intentions to invest in a variety of plans and figure out and measure what actually works. And... it'd be nice to have an open network left to do this on. For a reasonable price. P.S. Sorry for my "outburst." Just, exhausted with this whack-a-mole against moneyed self-interests that can afford to just keep trying again and again and again until they get their way. Because, they aren't about creating the most (absolute) value. Just capturing the most (relative) value, for themselves.
  • quadrangle 9y ago
    > law-abiding citizen Unfortunately, there really are enough laws that everyone is constantly breaking some. Selective enforcement can be used to shut up critics…
    • pasbesoin 9y ago
      And part of my point is that I am not calling for anything that would invoke several of them to rain down upon me. I only ask that the sleaze be held to the same standard...
• outsidetheparty 9y ago
  On page 15: > Following the 2014 Notice and in the lead up to the Title II Order, Internet service providers stated that the increased regulatory burdens of Title II classification would lead to depressed investment. To support this notion, they cite two reports that purport to show that capital expenditure by ISPs went down as a result of common carrier regulation. The first [1] has data only from 2014 on, so has hardly any "before" data; and shows wild enough variability in the "after" data that it seems unreasonable to draw any conclusions from the average value over such a short time frame. The second [2] is a convoluted enough statistical analysis that I'm not really able to evaluate it -- though it does appear to show that telecom investment in infrastructure appears to have grown at roughly the same rate as it had since the 1980s (save for some wild up and down swings prior to 2010) -- just not as fast as an invented "control group" of imaginary telecoms that never heard they might be classified as common carriers (see figure 3.) That's shady, right? It sure seems shady. [1] https://haljsinger.wordpress.com/2017/03/01/2016-broadband-capex-survey-tracking-investment-in-the-title-ii-era/ https://haljsinger.wordpress.com/2017/03/01/2016-broadband-c... [2] http://www.phoenix-center.org/perspectives/Perspective17-02Final.pdf http://www.phoenix-center.org/perspectives/Perspective17-02F...
  • ComradeTaco 9y ago
    ISPs, like all corporations, always have the best interests of their customers as heart. In the unlikely event that an ISP abuses their position another ISP startup will immediately spring up and start a brand new network.
    • glitcher 9y ago
      Yes, exactly. And now I am simply flooded with so many choices in ISPs that I hardly know which one to try next.
      • maskedinvader 9y ago
        this and parent comment is both sarcasm right ?
• exabrial 9y ago
  Does being reclassified as "Title 1 - Information Services" put them under the regulatory authority of the FTC instead of the FCC?
• drenvuk 9y ago
  The one question that I have is how do we stop this? Do I go somewhere to vote? Do I send a letter? Do I go to petition.org or something? Can I only donate to the EFF and that's it? What do I need to do to have a concrete affect on the outcome of this instead of just commenting here or in some other thread?
  • ep103 9y ago
    Al Franklin apparently just came out against this pretty loudly. So yes, I'd say the same steps as before, donate to politicans that come out against this, write letters / emails to your senators / representatives, and lodge a comment with the FCC. We saw under wheeler that while they can ignore that type of community activism, it absolutely has effects.
  • loteck 9y ago
    What you can do now to stop a political process that ended last November is: nothing. It's in the past. What you can do now to impact political processes in the near future (no policy is immutable, after all) is to work in your community to build consensus around policies you believe in, so that those policies are reflected in future decisions. I don't know when, but at some point we as a country of citizens got really bad at understanding this, it seems like!
    • sanderjd 9y ago
      Exactly. The thing to do is to convince people you know that this is a bad idea. I think there are lots of pro-small-business Republicans who see this as a good reduction in regulation that will benefit the dynamic tech entrepreneurship sector, and who would be surprised at its unpopularity within the hotbed of exactly those entrepreneurial techies that is HN. Most Republican voters are no friend to regulatory capture, they just haven't been convinced that's what is going on in this administration.
      • jay-anderson 9y ago
        Advice I've heard is to appeal to your audience's principles (moral reframing is the term I've heard it called: https://www.fastcompany.com/3067593/how-to-use-moral-reframing-to-persuade-conservatives-to-support-immigration https://www.fastcompany.com/3067593/how-to-use-moral-reframi...). In this case which principles that republicans/conservatives/etc. hold dear would provide good arguments for opposing this proposal? I don't think I have a good answer for that yet. Here are some ideas: - Personal Freedom: This change will allow ISPs to restrict or hobble sites you choose to go to. - Free market: This is allowing entrenched ISPs to restrict competition in what web sites we visit. Only the big players will be able to afford access artificially restricting the free market. - Purity: From what I understand this change hinges on the ability to define a broadband ISP as an information service rather than a telecommunication service. I could see an argument here that ISPs are attempting to use a loophole to skirt the law defining the service they provide. If anyone has ideas here I'd love to hear them.
• shmerl 9y ago
  Read as: Restoring Internet [Providers'] Freedom [from oversight]. Hypocrites.
  • donatj 9y ago
    Restoring networking equipment owner's control of their own property?
    • shmerl 9y ago
      Property isn't a problem. Using it in a way that monopolizes the market is. I.e. imagine you own a property which delivers water to the city. Saying that you can do anything you want with it is clearly a problem.
    • orthecreedence 9y ago
      > HAI GOVT CAN YOU HELP ME BUILD THIS INFRASTRUCTURE LOL > OK, BUT BE SURE TO... > OMG STOP TELLING ME WHAT TO DO ON MY OWN INFRASTRUCTURE!!!11 #FREEDOM
• coretx 9y ago
  This document is so incredibly professionally framed and laced with layers upon layers of spindoktering that I can't help to conclude that the FCC is intentionally violating the congressional statutes forming their mandate. Perhaps the EFF or similar should drag them in front of a judge.
• mundo 9y ago
  $99/month Family Freedom package: - 200GB "Streaming Gigs" for up to four authorized devices - 100GB "Gaming Gigs" (with Super-Ping technology!) - 25GB "Other" - Unlimited email, Facebook and Snapchat! Little glimpse in to our future, ladies and gents.
  • loader 9y ago
    What pisses me off is I get all that and more for less money already.
    • nebabyte 9y ago
      ...yes, welcome to the point?
  • colanderman 9y ago
    And that is when you configure an unused set-top box to stream new releases 24/7 to /dev/null.
    • nebabyte 9y ago
      - drop in the bucket - they won't actually care - your taxpayer dollars will already have done (likely continue to be doing) more than enough for them in the opposite direction - effectively amounts to neutralizing you the way signing a petition neutralizes others
• donatj 9y ago
  As someone who feels like this might be a good thing, can someone politely explain the objections?
  • CGamesPlay 9y ago
    This is about net neutrality; you can find objections anywhere. http://www.gadgetsnow.com/tech-news/What-is-net-neutrality-and-why-it-is-important/articleshow/46902071.cms http://www.gadgetsnow.com/tech-news/What-is-net-neutrality-a...
  • davesque 9y ago
    My (and many others') objections are that ISP's in the US have been known for a while to be lagging behind the curve across the world in terms of quality of service and pricing. On top of that, they actively lobby against competing startup ISP's and pull dirty tricks to prevent anyone else from entering the market. Now, they want to roll back laws preventing them from charging for traffic based on content. This will make it more difficult to guarantee consistent quality of service to consumers and may also prevent new technology businesses from getting off the ground. It may even lead to a de facto form of censorship if content that large players don't agree with can be throttled. I've heard the argument that it's their business and they can do what they want. The problem with this, however, is that they are providing a service that is essential and not a luxury. Historically, organizations whose main purpose is to benefit shareholders have not been very good at keeping the public's interests in mind. That's why the government needs to regulate services which are essential and why the ISP's have no argument here.
• finid 9y ago
  to preserve the future of Internet Freedom, and to reverse the decline in infrastructure investment, innovation, and options for consumers put into motion by the FCC in 2015. There has been a decline in innovation since 2015? How did they determine that? I must be missing something... Propose to reinstate the determination that mobile broadband Internet access service is not a commercial mobile service... Really! Commercial must have a special meaning here.
• glitcher 9y ago
  This seems to be a common theme in this administration to "restore freedoms" to corporations with bald-faced lies that they restore freedoms to individuals. The current rhetoric surrounding the recent order to review many national monuments is steeped in very similar twisted logic - that somehow the land needs to be "returned to the people". But wait, wasn't that national monument set aside exactly for preserving a small chunk of pristine wilderness for "the people"?
• deleted 9y ago
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• deleted 9y ago
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• pdonis 9y ago
  Here is an updated comment (thanks everyone for feedback!). Please feel free to pass this on to your elected representatives, or anyone else who you think should see it. Re: Notice of Proposed Rulemaking – WC Docket No. 17-108 The subject notice seeks comment on the analysis provided. The following comments are hereby submitted. Paragraph 27 purports to show that broadband Internet service is an information service because it provides users the "capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information via telecommunications." The argument given is that broadband Internet service allows users to do all these things. However, this is not the same as providing the capability to do these things. To see why, consider that providing users Internet services over dialup phone lines also allows users to do all these things; but the phone lines themselves are telecommunications services, not information services. Why? Because providing the user dialup Internet, by itself, does not provide them the capability to do all these things. That capability is provided by the endpoints: the users' computers, and the computers hosting the Internet services that the users connect to. Exactly the same is true of broadband Internet services provided by ISPs: by themselves, they do not provide users the capability to do all these things. They only provide connections between computers at the endpoints that provide those capabilities. It is the services provided by the Internet hosts that users connect to that are "information services". The broadband Internet services that allow users to connect to those hosts are telecommunications services, and should be regulated as such. ISPs object to analyses like the one above because they claim that they also provide the actual information services--in other words, they also provide Internet hosts that function as email servers, web servers, etc. But it is obvious that those services are separate from the broadband connection services provided by those same ISPs, because users can make use of the latter without making use of the former at all. I am such a user: I use the broadband Internet connection provided by my ISP, but I do not use any of the information services they provide; I do not use their email, their web hosting, etc. I use other Internet hosts provided by other companies for those services. The fact that ISPs offer information services as well as telecommunications services does not make their telecommunications services into information services; an ISP's choice of business model cannot change the nature of a particular service it provides. Broadband Internet connections are obviously a telecommunications service, and should be regulated as such, regardless of what other services ISPs would like to bundle with them. Paragraph 28 asks whether "offering Internet access is precisely what makes the service capable of 'generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information' to consumers?" The answer to this question, as noted above, is no, because all of those capabilities are not provided by the mere fact of Internet access; they are provided by the endpoint computers that implement those capabilities. The question of how those computers are connected to each other, which is the relevant question for the purpose of determining whether broadband Internet service is a telecommunications service, is a separate question from the question of what capabilities the endpoint computers provide. Paragraph 28 also asks whether consumers could "access these online services using traditional telecommunications services like telephone service or point-to-point special access?" Obviously the answer to this question will depend on what connectivity the providers of such telecommunications services choose to provide. But that is a different question from the question of what the nature of a particular service is. Again, the question of how computers are connected to each other is separate from the question of what capabilities the endpoint computers provide. Paragraph 29 attempts to argue, in effect, that if most Internet users rely on their ISPs for any additional service beyond the bare fact of Internet connectivity--for example, DNS--then broadband Internet service must be an information service. Paragraph 29 also claims that the ISP, not the user, "specifies the points between and among which information will be transmitted", because, first, users only specify domain names, not IP addresses, and second, users do not make the routing decisions that determine the specific path information packets take through the network. Neither of these considerations affects the proper classification of broadband Internet service as a telecommunications service. Users might only specify domain names, but the service of translating domain names into IP addresses is provided by an endpoint--a DNS server--not by the bare provision of an Internet connection. (And even if the ISP typically provides this endpoint, that is still a separate service from the service of providing an Internet connection, and, as above, bundling the two together cannot change the nature of the latter.) Once the DNS service has provided an IP address corresponding to a domain name to the user's computer, the user's computer, not the network, specifies that IP address as the target of information packets, so once again, it is an endpoint, not the network itself, that determines where the information goes. And routing information packets, in and of itself, is not an information service, because it does not change the information being routed; it just accomplishes the information transmission specified by the user, from one endpoint to another. The intermediate routers that pass on information packets are not endpoints: they are not specified by the user as the targets of any information, and they do not provide any of the capabilities that make an endpoint a provider of an information service. The analysis of Paragraph 29 also fails to take into account that, if it were valid, it would apply equally well to traditional phone service, which is admitted to be a telecommunications service. Users specify phone numbers to dial, but that does not require knowledge of the physical location of the target phone (and the user will often not have such knowledge), nor does it specify the route that will be taken by the information transmitted by the call. Also, traditional phone service includes directory service (411) and other "add-ons" that go beyond the basic provision of a connection. What makes those "add-ons" telecommunications services rather than information services is that they are for the purpose of facilitating the connection (or facilitating the refusal of connections which are not desired), rather than acting on the information exchanged between the users at the endpoints. Paragraph 30 attempts to argue that network management activities such as firewalling and IPV4 - IPV6 translation constitute changing the information being transmitted. This analysis fails in two ways. First, refusing to transmit information (e.g., a firewall blocking content deemed to be harmful) is not the same as changing it. Refusing to provide a connection to a user is not the same as changing the information transmitted by the user. Second, the "information" which is changed by such activities as IPV4 - IPV6 translation is not the information sent by the user; it is network management information which is added to the information packets specified by the user, outside the user's control and indeed without the knowledge of most users (since most users are not familiar with the technical details of IP networking). These network management activities are no different from the activities routinely performed by phone networks to route calls--indeed, today the same physical infrastructure is often used to perform both functions, since the phone service backbone and the Internet backbone are in many cases the same networks. Similar remarks apply to services such as filtering by firewalls: phone networks can block calls from certain numbers, for example. Again, the key distinction which the analysis in Paragraph 30 fails to make is between "add-on" services that are for the purpose of facilitating connections, and services that are for the purpose of manipulating the information exchanged by the users at the endpoints. Only the latter are information services; the former are part of the telecommunications service that provides the connection. In the light of all of the above considerations, the FCC should continue to regulate broadband Internet service as a telecommunications service.
• sesteel 9y ago
  Time for another march? We are having them weekly as of late. Organized anger can be a powerful tool.
  • orthecreedence 9y ago
    "Paid protesters march for internet socialism. Sad!"
• icey 9y ago
  I've been working on a tool to help people team up and discover important facts from documents like this. It's still very early going, but I've uploaded the document here: https://docsift.com/docs/restoring-internet-freedom-notice-of-proposed-rulemaking-fcc/ https://docsift.com/docs/restoring-internet-freedom-notice-o... At the very least, it will provide an easy way to share links to specific pages of the documents (of course, you can add notes and annotations to the pages, and there's been some rudimentary fact extraction done already). I just loaded the document a moment ago, so I haven't had a chance to scan through and make sure all the details are correct, but wanted to share it so folks can scan through it now. Feedback is definitely welcome, and I'll hold off on doing non-critical deploys today so it stays up while people read it. I've only been working on it for a few weeks so there's still quite a lot to do :)
  • givinguflac 9y ago
    Pretty cool, you should make a dedicated post when you finish!
  • appleflaxen 9y ago
    that's fantastic! Cool project!
• gojiberry 9y ago
  BS. Trump and Republicans just want to screw everybody. Whatever rules/bills they call 'freedom' are all actually anti-freedom.
• RcouF1uZ4gsC 9y ago
  One thing is interesting is that Google Fiber rollout slowed down with the Net Neutrality rules. Maybe they did not see it as quite as vital to their business. Now with Net Neutrality gone, given they view an open Internet as vital to their business, they actually may give more priority to Google Fiber.
• devoply 9y ago
  Restoring corporate tyranny.
• astaroth360 9y ago
  And so the internet dies...
• arcbyte 9y ago
  ISPs should be able to manage their networks without government incompetence. As smart as everyone here is when it comes to building internet endpoints, most of these comments betray an utter lack of understanding of what goes on in the ISP level.
  • quadrangle 9y ago
    could you be specific about the "most of the comments"? Most of what I see isn't even relevant to the technical on-the-ground details about ISPs. Most comments are just about the idea of whether ISPs that have monopoly/oligopoly status will be permitted to violate net neutrality. What of "what goes on in the ISP level" that is even insightful to bring up?
    • Can_Not 9y ago
      He's saying that if he wants to sell "Chicken Noodle Soup" with zero chicken in it, that's his God given right and if we could only remove those pesky regulations the free market will set us free.
• nikolasavic 9y ago
  PBS NewsHour: FCC chair Ajit Pai explains why he wants to scrap net neutrality https://www.youtube.com/watch?v=6Q5_oV4JB10 https://www.youtube.com/watch?v=6Q5_oV4JB10
• theprop 9y ago
  Why isn't this called "Protecting the Internet for Patriots"?
  • quadrangle 9y ago
    Because that would sound like foreign terrorists are the concern. For this issue, the goal is to present the enemy as being government and anyone who supports government regulation of any sort.
• djyaz1200 9y ago
  To whom it may concern at the FCC, As the head of an ISP I must tell you that I am entirely dissatisfied with the billions of dollars I make providing a mediocre utility service with near zero competition to customers who pay for that service. I see the billions of dollars being made by Facebook and Google through innovation and user consent and I want to take that money with political and regulatory force. I'll need you to first make it entirely legal for me to capture and sell all data about my users. Not because they consent, not because they want this but because I want a new cash cow to slaughter. I'm going to use this information to become an alternative provider of targeted ads to my customers. Next, I'll need you to allow me to throttle back the speed by which customers can access my competitors services because mine aren't as good. This isn't so much a toll road as a team of aggressive traffic cops, pulling over any business making too much money on my big dumb pipe to slow them down... fine them and then let them slowly attempt to carry on. I need this all because I don't innovate, I don't like my customers or give a shit what they want. I am simply used to using raw power and corrupt regulatory force to act as a parasite extracting the maximum tariff from productive businesses, people and entrepreneurs possible while keeping some of my hosts alive... but killing the smaller ones. I am big business. I am angry because I am losing. The actual free and open internet is allowing actual free market capitalism and user choice in too many things. I used to fight this kind of thing in back rooms quietly but this fight has escalated so now I must come out in the open and ask the government publicly to please take from the poor and give to me in new ways... because the poor keep innovating their way out of the traps I set. Finally, I disrespectfully request that the rules I propose be named the exact opposite of what they stand for, so it's clear this isn't a discussion with reasonable people but a raw show of force. -Old Rich Guy
• theprop 9y ago
  The funny thing is that this will likely lead to a lot more significant losses in online privacy. The ISPs will now extort money from Google/YouTube, Netflix, Facebook, and Amazon...at least two of whom will need to track users more in order to better target ads (since they're already at max-ad-display thresholds) to increase ad yields. So to generate more revenues to feed ISP extortion, it's likely to drive companies to track you further.
• deleted 9y ago
  [deleted]
• TheSageMage 9y ago
  Is the argument here that if "net neutrality" goes away, carriers will provide service to "poor, rural area" because they are able to serve their content better than the generally available content on the internet? Not arguing for it, just trying to understand the argument for a less "equal" internet. Also, I thought this was how it already worked, but it was just called home cable? Don't most homes in the US got a decent hookup to their home for "cable", that usually includes an internet package?
  • quadrangle 9y ago
    I think the argument is this: "The best possible service for customers always necessarily comes from unregulated free-market competition. Therefore, we should remove all regulations, even if they are removed one-by-one with potential imbalances occurring in the regulatory ecosystem. Removal of any regulation is at least closer to true free market. So, we'll start with removing the regulations that my lobbyist friends identify as the ones they most want removed. It's a step in the right direction. Since fewer regulations equals more market freedom, whatever happens will necessarily be an improvement overall compared with whatever would have happened with the regulation in place." In short: "free markets are the best because whatever result we get from whatever we choose to call free markets is, by definition, the best result."
    • thomastjeffery 9y ago
      The argument is not an argument at all, but an appeal to ideology. Ironically, the ideology that is appealed to is the best argument for net neutrality.
      • dragonwriter 9y ago
        > The argument is not an argument at all, but an appeal to ideology. All arguments for policy (or action more generally) are, at root, appeals to ideology. You can't get "should do" results anywhere else.
      • quadrangle 9y ago
• bluejekyll 9y ago
  Anyone notice that they took the PDF down?
  • t3f 9y ago
    The OP linked to their daily feed which isn't quite an anchor. The actual docket landing page is at [0] and pdf at [1]. Their "Fact Sheet" is also at [2] and [3]. [0] - https://www.fcc.gov/document/public-notice-filing-comments-restoring-internet-freedom https://www.fcc.gov/document/public-notice-filing-comments-r... [1] - https://apps.fcc.gov/edocs_public/attachmatch/DOC-344623A1.pdf https://apps.fcc.gov/edocs_public/attachmatch/DOC-344623A1.p... [2] - https://apps.fcc.gov/edocs_public/attachmatch/DOC-344592A1.pdf https://apps.fcc.gov/edocs_public/attachmatch/DOC-344592A1.p... [3] - https://apps.fcc.gov/edocs_public/attachmatch/DOC-344592A1.pdf https://apps.fcc.gov/edocs_public/attachmatch/DOC-344592A1.p... @mods could the OP URL get updated to the anchor url for folks searching later? -edit, formatting
• mirimir 9y ago
  That URL seems dead. This one works: https://apps.fcc.gov/edocs_public/attachmatch/DOC-344614A1.pdf https://apps.fcc.gov/edocs_public/attachmatch/DOC-344614A1.p...
• lbarrett 9y ago
  I posted a comment! Hooray for participation in government.