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Open Letter to the FCC on Net Neutrality

I submitted this letter to the FCC on June 5, 2014 in response to 14-28 Protecting and Promoting the Open Internet.

The Federal Communciations Commission (FCC) should not finalize this proposed rule.

Despite the admirable name, this rule neither protects nor promotes an open internet. Rather, the rule grants internet service providers additional undue advantage in a system already crippled by monopoly power.

The vast majority of consumers have one or fewer options for broadband internet. When Comcast decides to increase the cost of my basic internet package from $35.99 to $49.99 and finally in excess of $60 per month* over the course of 8 months, I have no recourse. To access the internet at home, the most affordable option is to subscribe with Comcast. This will remain true up until their prices exceed that of the already exorbitant ones charged by mobile telecommunications providers, like Verizon.

In return for my monthly payments, Comcast offers spotty service that is frequently slow when processing high-definition video streaming. Imagine my chagrin when I discovered that Comcast deliberately decreases download speeds during hours of peak use. The kicker is that this decision comes far in advance of demand reaching–let alone exceeding, the existing capacity on the Comcast infrastructure.

The implications are clear. When internet service providers do not have any meaningful competition for broadband cable internet access, they can charge consumers rates that are disconnected from reality and offer service that fluctuates in quality at a whim. This does not have to be the case.

Let’s consider the example of the United Kingdom, as highlighted in a recent NPR Planet Money episode titled, “The Last Mile.” In that program, the Planet Money team discussed the change that UK regulators promulgated in response to the very same issues that we are experiencing today. Rather than permit internet service providers to charge content producers for access to so-called high-speed lanes, the UK introduced a model similar to landline telephones. Instead of a single company monopolizing the cable line, many companies sell internet access to consumers over the same wires.

The UK experience has led to a dramatic uptick in both the number of high-speed, broadband internet providers and the quality of service. Consumers in the UK also pay dramatically less.

I understand why Comcast and other internet service providers would prefer the fast-lane approach that you are proposing. Many are also cable television providers. These providers receive subscription payments from consumers, and then pay content producers for the privilege to include their channel in the cable bundle. That flow from consumer to cable provider and finally content producer is long established. Your proposal would upend the model from that industry and have both consumers and content producers pay broadband cable internet providers for the privilege to interact with each other online. That creates windfalls for Comcast, but offers no guarantee to either party that they will see investment in the infrastructure and service that we believe our dollars should afford.

Unfortunately, overpriced service for subpar quality is commonplace in America–just look at healthcare. But let’s not treat this reality as an inviolable part of the American Dream. Instead, the FCC should promulgate rules that can imbue this industry with meaningful competition to truly protect and promote the open internet.

*Update: After speaking with the Customer Retention Department at Comcast, I was able to decrease my bill $10 to $56.95 per month (for 12 months). That is a nearly 63% increase from the starting price of $34.99 per month, but at least better than the over 91% increase that would have occurred. 




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