Today is the last day you can submit public comments to the FCC about their critically-flawed "open internet" (or net neutrality) plan. CREDO helps you write the FCC, while Sum of Us helps you call the FCC -- and why not? Shouldn't we should occupy their phone lines as surely as we occupy their email inboxes? The Consumerist, of course, still helps you tailor your comment to the FCC's proposal; they also provide a withering takedown of big telecom corporations' arguments against net neutrality, which seem to amount to WAAAAH I HATEZ TEH REGULASHUNZ!!!!!
I've attached here my own comment, which I submitted to the FCC yesterday; you may find it instructive as you consider what to say in your own comment.
The FCC has asked the public for comments on docket 14-28 on the Open Internet, and as both a user and a producer of web content, I offer my comment for consideration by the commission, in the hope that we may preserve a free and open internet for all Americans. And, since I was trained at school many years ago (never mind how many) to refute my opponents' arguments fist, I will dispense with that task.
Net neutrality opponents typically claim that regulations like those that 14-28 would issue "stifle innovation and investment," a claim that mainstream media news organs (which accept advertisement money from big telecoms, or may even own or be owned by them) often treat as gospel. But the greatest innovations of the internet era -- including broadband, weblogs, alternative news sites, video sharing, and social networking -- all occurred while big telecom corporations observed a net-neutral file-sharing arrangement. And, as Chairman Wheeler has said, "investment increased for both edge providers and in broadband networks" since the FCC's 2010 Open Internet Order; Chairman Wheeler adds that "since 2009, nearly $250 billion in private capital has been invested in U.S. wired and wireless broadband networks." I should add that this investment spike occurred in an economically-depressed atmosphere. And believing that regulations inherently "stifle innovation," as so many net neutrality opponents seem to believe, requires that one also believe that any law stifles freedom, which we know not to be true, or that laws cannot promote freedom, which we also know not to be true. Certainly the Clean Air Act, for example, hasn't "stifled innovation" of energy producing corporations that have to figure out how to engineer their plants so they pollute less, nor has it stifled the freedom of the folks who are much freer from asthma and cancer than they'd be without the Clean Air Act.
On to the FCC's proposal, then. The FCC has asked whether it should ban internet "fast lanes" outright. I say that yes, it must, because faster delivery of content from corporations that pay more for it would not "encourage innovation," but would actually stifle innovation. Large corporations are temperamentally conservative -- no large corporation came up with, nor would have come up with, Instapundit, YouTube, Daily Kos, Google, or Facebook, since all these innovations were, at one time or other, disruptive of the corporation's main mission, which is to preserve and increase profits. But internet fast lanes would also stifle innovation: all of the aforementioned innovations (two of which are have since become big telecoms themselves, while one of them owns a third) came from small, independent actors, who would not have been able to give their innovations to the world if they had to pay an exhorbitant fee to the established players just to get adequate service. Simply put, the startup costs of a viable media operation have never been lower -- when I started my own weblog, Thieves in the Temple, server space cost me a little over a dollar a month, and even now, as I'm building a larger audience for the blog than it's ever had, advertising costs are far from prohibitive, which I attribute to the disruptive technologies that much larger corporations didn't pursue until they saw that people liked them. An extra layer of "fast lane" fees would almost certainly kill this blog, and why shouldn't it live or die on its merits, rather than at corporate America's will?
The FCC also asks if it should reclassify broadband as a Title II "common carrier," which would essentially allow it to regulate broadband as a public utility. Again, I say it must, because broadband has basically become a public utility, as television was before the advent of cable, as water and electricity service were once luxuries that have now become necessities. I think Section 706 of the Telecommunications Act (as the D.C. Circuit Court suggests would provide authority for net neutrality regulation) concerns itself mainly with internet access in public schools and infrastructure investment, and thus isn't the better tool for enforcing vigorous net neutrality regulations than Title II reclassification.
The FCC also asks whether the Open Internet rules should apply to wireless broadband. Again, it must. I assume that wireless broadband will one day (though perhaps not soon) become the industry standard for broadband, but I do not see what is otherwise unique about it that it should be exempt from net neutrality rules. Wireless technology isn't that good, frankly, but the technology will improve not when corporations are "free" from having to give all content equal treatment, but when consumers demand it, and when one corporation delivers it and sets the market standard higher. Large telecom corporations, again, don't need to be let out of the rules so they can spend money to make the necessary upgrades to wireless systems; they have the money now and can spend it now, except that most of them are too stuck in their ways to do it. Again, this is a case where the government would promote freedom (for the consumer, that is) by mandating a corporate behavior, rather than assuming that letting corporations do what they want itself constitutes "freedom."
Finally, I support ending "legal restrictions on the ability of cities and towns to offer broadband services to consumers in their communities." Such restrictions enacted at the state level seem to me little more than a welfare handout to large telecom corporations, whose leaders, ironically enough, often brag about how they can do broadband better than any government could. If they were so sure about that, they would not mind the competition from state and local governments as much as they seem to do. And ending restrictions on municipal wireless services would also help rural and urban communities gain such services, since the big telecom corporations rarely build out into these areas of the nation. You don't deserve worse service just because you live in rural America, and we should concern ourselves, as a nation, with getting rural areas broadband service, and not so much with figuring out what carrot and what stick will induce large telecoms to do it.
Again, I urge your commission to write the most vigorous net neutrality rules possible, so that we may protect the consumer and the small businesses responsible for most internet innovation. Large corporations don't need our government looking out for their interests -- their wealth and position assure them a seat at the policy-making table. But ensuring the most freedom for the most people means, generally, that our government must protect the smaller actors in a marketplace. Doing so does is not "anti-freedom," because we should not measure freedom exclusively as a function of how rich our richest citizens can get. Doing so is pro-freedom, because we all benefit, and we all become more free, because of the small business innovation that is itself free of the corporate mindset. I thank you for your time and attention.