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I think a great thing to do (if you are for net neutrality), is pick specific parts of the NPRM filed with this proceeding and comment directly on it[1] to help
by alexanderdmitri 9y ago
I think a great thing to do (if you are for net neutrality), is pick specific parts of the NPRM filed with this proceeding and comment directly on it[1] to help do some work for the defense. I feel sorry for anyone who might actually need to address this document point for point to defend net neutrality.
I tried my hand at the general claim of regulatory uncertainty hurting business, then Paragraphs 45 and 47:
-> It is worth noting that by bringing this into the spotlight again the NPRM is guilty of iginiting the same regulatory uncertainty it repeatedly claims has hurt its investments.
-> Paragraph 45 devotes 124 words (94% of the paragraph), gives 3 sources (75% of the references in this paragraph) and a number of figures (100% of explicitly hand-picked data) making the claim Title II regulation has suppressed investment. It then ends with 8 words and 1 reference vaguely stating "Other interested parties have come to different conclusions." Given the NPRM's insistence on both detail and clarity, this is absolutely unacceptable.
-> There are also a number of extremely misleading and insubstantiated arguments throughout. Reference 114 in Paragraph 47, for example, is actually a hapzard mishmash of 3 references with clearly hand-picked data from somewhat disjointed sources and analyses. Then the next two references [115, 116] in the same paragraph, point to letters sent to the FCC over 2 years ago from small ISP providers before regulations were classified as Title II. Despite discussing the fears raised in these letters, the NRPM provides little data on whether these fears were actually borne out. In fact, one of the providers explicitly mentioned in reference 115, Cedar Falls Utilities, have not in any way been subject to these regulations (they have less than 100,000 customers ... in fact the population of Cedar Falls isn't even 1/2 of the 100,000 customer exemption the FCC has provided!). This is obviously faked concern for the small ISP businesses and again, given the NPRM's insistence on both detail and clarity, this is absolutely unacceptable.
[1] makes a great point on specifically addressing what's being brought up in the NPRM:
https://techcrunch.com/2017/04/27/how-to-comment-on-the-fccs-proposal-to-revoke-net-neutrality/ https://techcrunch.com/2017/04/27/how-to-comment-on-the-fccs...