To the FCC,
Your new rules as written do not provide solid consumer protection or any guarantee of an open Internet. To the contrary, cable and telcos (ISPs) are duopolies or monopolies in most areas of the country and have already shown a propensity for charging ridiculous prices with onerous terms under one-sided contracts. For example, I run a small business with 2 sites. Last winter Time-Warner Cable, with whom I have a business Internet account, called to tell me that they were lowering my bandwidth, doubling their prices, and requiring a one year contract. I had 48 hours to agree to these terms or my service would be disconnected. I half expected to see a leg-breaker with a baseball bat show up at my door. Time Warner is the only provider at this location, so I had no choice.
ISPs bemoan that use of services by providers such as Google, Amazon, and Netflix use too much bandwidth, but those companies aren't getting a free ride. They pay millions of dollars a year for infrastructure and bandwidth. The consumers that use their services are likewise charged monthly per contracted level of bandwidth by the ISPs. Consumers are already getting short changed, as the ISPs do not provision for full use by all concurrently. I might pay for 30Mb/sec of bandwidth, as do my neighbors, but if we all attempt to download large files at the same time we will find that the "pipe" that we share is not large enough to allow us the bandwidth for which we pay.
The ISPs claim that because consumers are using bandwidth to watch, for example, Netflix that Netflix must pay them as well. This is not only double dipping, it is actually using the fact that they oversell bandwidth to their customers as an excuse to lobby for payment for traffic priority by providers. This is outrageous.
The oft quoted "fast lane" is a canard. The ISPs aren't going to invest in a separate "fast lane". They are going to use Quality of Service bandwidth shaping to prioritize traffic if paid by a service provider, at the expense of other traffic. So if the same group of neighbors all try to download at the same time, but one is watching Netflix (and Netflix pays the ISP for priority), the movie watcher's data stream will be unaffected. The others suffer.
If the FCC approves this plan as written it will be to the benefit of some of the largest corporations in the country, companies that rank annually at the bottom of customer satisfaction surveys, at the expense of consumers and small businesses.
The FCC should be going in exactly the opposite direction; endeavoring to encourage competition and discouraging price gouging.
Regards,
Richard Bross
