Tuesday, July 10, 2007
My comment on FCC's Network Neutrality NOI
You too can file an FCC comment using this form. It's easy! The deadline is next Monday, July 16! (Unlike voting, you CAN file early and often -- the carriers certainly do.) You can make the comment brief, e.g., "Fast Pipe, Always On, Get Out of the Way!" but you should file by Monday.
My comment:
I notice that the FCC's NOI document of March 22, 2007, WC Docket No. 07-52, to which this Comment is addressed, "found no evidence that [broadband providers] were operating in a manner inconsistent with the Policy Statement." The Policy Statement (doc, .pdf), formerly known as the Four Internet Freedoms, has the effect of stating that customers are entitled to use the Internet to access content, run applications and services, and attach devices to the Internet, as long as the law is not broken and the network is not harmed. The fourth "Freedom" -- to have clear, explicit service plan information -- has been supplanted by a vague entitlement to competition.
The focus of the current NOI is wireline-based broadband service, yet recently the FCC has included wireless broadband service in its US broadband deployment statistics [.pdf], and the current NOI makes no distinction between wired and wireless casrriers, asking for, "a fuller understanding of the behavior of broadband market participants today, including network platform providers, broadband Internet access service providers, other broadband transmission providers, Internet service providers, Internet backbone providers, content and application service providers, and others."
It has recently come to my attention that most mobile (cellular) broadband terms of service severely restrict customer choice in the accessing of content, the running of applications and services, and the attachment of devices.
The FCC shouldn't have it both ways. If wireless broadband services are to be included as broadband services, they should be subject to the Policy Statement. On the other hand, if they're not held to the Policy Statement's principles, such crippled, attenuated should not be included in the FCC's broadband statistical report.
My comment:
I notice that the FCC's NOI document of March 22, 2007, WC Docket No. 07-52, to which this Comment is addressed, "found no evidence that [broadband providers] were operating in a manner inconsistent with the Policy Statement." The Policy Statement (doc, .pdf), formerly known as the Four Internet Freedoms, has the effect of stating that customers are entitled to use the Internet to access content, run applications and services, and attach devices to the Internet, as long as the law is not broken and the network is not harmed. The fourth "Freedom" -- to have clear, explicit service plan information -- has been supplanted by a vague entitlement to competition.
The focus of the current NOI is wireline-based broadband service, yet recently the FCC has included wireless broadband service in its US broadband deployment statistics [.pdf], and the current NOI makes no distinction between wired and wireless casrriers, asking for, "a fuller understanding of the behavior of broadband market participants today, including network platform providers, broadband Internet access service providers, other broadband transmission providers, Internet service providers, Internet backbone providers, content and application service providers, and others."
It has recently come to my attention that most mobile (cellular) broadband terms of service severely restrict customer choice in the accessing of content, the running of applications and services, and the attachment of devices.
The FCC shouldn't have it both ways. If wireless broadband services are to be included as broadband services, they should be subject to the Policy Statement. On the other hand, if they're not held to the Policy Statement's principles, such crippled, attenuated should not be included in the FCC's broadband statistical report.
Technorati Tags: Broadband, Broadband-per-capita, FCC, NetworkNeutrality, Regulatorium, WirelessNetworks
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