Today, we submitted reply comments, together with China Tech Threat, to the Federal Communications Commission regarding the reimposition of net neutrality rules. Click here to download a pdf of the comments.
Executive Summary
The Foundation for American Innovation (FAI) and China Tech Threat (CTT) appreciate the opportunity to submit reply comments to the Federal Communications Commission (FCC) concerning its proposed Notice of Proposed Rulemaking (NPRM). We observe that the number of comments for the proceeding, some 50,000 comments as of this writing, has plummeted since the Restoring Internet Freedom Order proceeding generating almost 3 million, and some 4 million for the Open Internet Order. This large drop in comments suggests that the issue is no longer politically salient, and as such, should be shelved. Moreover, the leading Title II supporters have almost nothing to say about the link between national security and Title II, suggesting as we observed in the first round, that the FCC’s assertion that Title II would improve national security is contrived, unfounded, and untheorized. If anything, Title II supporters are instead that edge providers would be enjoined into the FCC proffered national security measures per Title II.
However, many important, meaningful comments on national security were submitted by broadband providers’ trade associations. They detail how the FCC’s one-off imposition with Title II disrupts the Biden Administration’s official “whole-of-Nation approach to national security.”
Finally, little to no new commentary emerged explaining the link between Title II and public safety. The Santa Clara incident, the cause célèbre driving supporters to impose Title II on public safety grounds, remains an isolated incident, and ultimately unrelated to net neutrality, more than six years ago.
