Filing a comment
The FCC site is not the most intuitive site in the world.
- To file a comment, one must first go the FCC’s electronic filing system.
- Once there, click on “Search for Proceedings” and you will end up on a form.
- All you have to know is the proceeding number. In the case of net neutrality, that number is 09-191
- Enter 09-191 in the box that says “Proceeding Number” and click the “Search for Proceedings” button
- You’re now pretty close. As long as “Status” is Open, you can file a comment.
- Towards the top of the page, you will see a link to “Submit a filing for 09-191” (you can skip the earlier steps if you want and just click on the link here) or you can look at what comments have been made already.
- Of note, you can’t file the comment via a web form. You need to upload a document with your comment in it. A bit of an extra hassle but well worth it to protect the net.
- Make sure that you filled all the required fields or your comment could get rejected.
- Once you filed your comment, you’ll get a confirmation number and a page where you can check the status of your filing (mine can be seen here)
- That’s it. Remember that the deadline is Thursday, January 14, 2009 so please do keep this in mind.
What I filed
Looking at the recent talks around the concept of net neutrality, I decided that I would just tackle some of the arguments against it, showing them to be based on nothing more than FUD. So I focused my comment on a small section of the findings.
Here’s what I said:
As mentioned in the introductory paragraphs of your proposed rule-making, the internet openness has not only been key to its success but also provided entrepreneurs like myself with the ability to foster economic growth by creating new companies and new jobs.
To create a multi-tier system, as parties opposing further actions by the commission (as highlighted in III, item 65), has the potential of creating certain financial barriers that would prohibit innovation within the internet space. Let us not forget that, while Skype is often used as an example of how successful broadband access can enable new business models, that company (and a number of similar broadband-based offerings) was born outside of the United States at a time when broadband costs were cheaper in Europe than they were in the United States.
While the assertion that certain types of traffic can impose greater burden on a network, this has unfortunately been the case for much innovation. Web traffic created greater burden on the phone network in the early 1990s. Chat services and instant messaging created a greater burden on the networks in the later 1990s. Voice Over IP, online video, music stores like iTunes and online games like World of Warcraft have created a greater burden on the networks. Yet each of those legal applications has provided not only a new set of benefits in the form of new communications channels or new ways to deliver entertainment but also improved the country’s economy by providing some new engines for economic and job growth. It is not impossible that, in the not so distant future, we would come to see the internet as the carrier of data of voice for any application, whether it is high definition 3D TV channels, or high definition video telephony.
Third, the assertion that higher costs are required in order to foster innovation seems to be counter to the actual data available in the marketplace. While it is clear that investing in new infrastructure spend is expensive, much of the costs currently needed to provide broadband access to large portions of the country are already sunk cost as the telecommunication and cable industry overspent in the 1990s on laying down fiber that, to this day, is often still unlit. Investing in new technology to enhance the performance of networks is generally not the domain of those providers who are advocating a less open system as they generally do not research and invent the tools that allow for better network management. Network improvements, in the final economic analysis, generally happen because the providers see a competitive advantage in improving the network, not because of network discrimination.
As a result, most of the arguments made in favor of network discrimination amount to scare tactics that have little basis in historical facts. I dare hope the commission will see through this subterfuge and provide full support for the principles of net neutrality highlighted in your document.
I’m not generally asking much of my audience but, in this case, I will make an exception and ask you to please go and file a comment before Thursday. The future of the internet is in your hands: whether you want to keep the net open is up to you but you have to act now.