They're not just trying to preempt any hypothetical disclosure "rules" but to make generally-applicable fraud and misrepresentation laws inapplicable to ISPs.

They're not just trying to preempt any hypothetical disclosure "rules" but to make generally-applicable fraud and misrepresentation laws inapplicable to ISPs. New York, for instance, is suing Charter for lying to customers about lots of things not even covered by FCC policies; this is the lawsuit that prompted this effort by the ISPs.