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As the initial consultation period for the FCC’s proposed net neutrality rules comes to a close, major players are making their voices heard, with Comcast filing its comments in the proceeding.
David L. Cohen, Executive Vice President and Chief Diversity Officer in Open Internet, said that in its filing, Comcast was clear: “Comcast is for a free and open Internet and for legally enforceable rules to protect the Internet. We agree with the FCC that ‘[t]he Internet is America’s most important platform for economic growth, innovation, competition, free expression, and broadband investment and deployment’. For this reason we support the FCC putting in place legally enforceable rules to ensure that there is a free and open Internet, including transparency, no blocking, and anti-discrimination rules,” he declared.
“We publicly and strongly supported the FCC’s 2010 Open Internet Order. We did not seek to challenge those rules in court or otherwise. We believe they represented the proper balance between protecting consumer interests and respecting our rights to manage our network reasonably and maintained our incentives to invest and thereby empower more and more innovation on the Internet,” he advised.
“Our support of the 2010 Open Internet Order was so strong that we voluntarily agreed in our NBCUniversal transaction to be bound by those rules even if they were struck down by the courts. As a result of the DC Circuit decision and our commitment, we are now the only ISP in the country legally bound by the entire set of Open Internet rules,” he observed.
“Now that the DC Circuit has struck down the 2010 Open Internet Order, we continue to believe that the FCC should put in place legally enforceable rules to protect the openness of the Internet and we are strongly supportive of the FCC Chairman’s efforts to do so – and to do so quickly. We believe that the DC Circuit’s decision has, for the first time, laid out a clear path and clear authority (under section 706 of the Telecommunications Act) for the FCC to adopt robust and legally enforceable Open Internet rules,” he stated.
He said that Comcast did not support reclassification of broadband as a telecommunications service under Title II for at least four reasons:
Title II is unnecessary, given the broad scope of authority laid out by the DC Circuit under section 706;
Title II poses significant legal risks thereby ensuring that any open Internet rules adopted pursuant to such a reclassification would be subject to years of additional litigation;
Title II has proved to be a failure in regulation that has stifled investment and innovation (think POTS; highways; and utilities); and
reclassification of broadband under Title II will create a huge cloud of uncertainty over the entire broadband industry, thereby retarding investment and innovation.
“Since 1996, broadband providers have invested a staggering $1.2 trillion in our networks in the United States, which we have used to provide consumers in virtually every corner of the country with increasingly robust access to the open Internet,” he advised.
“For our part, we offer broadband to over 50 million homes and business, have increased broadband speeds 13 times in the last 12 years, and now provide our residential customers with speeds up to 505 Mbps. We are the only company in America legally bound by the 2010 FCC’s Open Internet rules and believe there should be rules that govern the industry as a whole. In fact, when we close our transaction with Time Warner Cable, we will extend our commitment to support the Open Internet rules to millions of additional broadband customers in Time Warner markets. In the meantime, we will continue building a secure and open Internet so all of our customers can have the best possible online experience in order to inspire innovation and promote competition,” he confirmed.