Mozilla Submits Comments on FCC Net Neutrality Proposal

Chris Riley


Today, Mozilla is filing comments in response to the first of two major deadlines set out by the U.S. Federal Communications Commission (FCC) for its latest net neutrality proposal. The FCC describes these rules as a means of “protecting and promoting the open Internet,” and we are encouraging the FCC to stay true to that ideal.

The FCC’s initial proposal offers weak rules, based on fragile “Title I” authority. The proposal represents a significant departure from current law and precedent in this space by expanding on a new area of authority without establishing clear limits. This approach makes it likely that it will be overturned on appeal.

Our comments, like our earlier Petition, urge the FCC to change course from its proposed path, and instead use its “Title II” authority as a basis for real net neutrality protections. We recommended that the FCC modernize the agency’s approach to how Internet Service Providers (ISPs) provide Internet access service. Specifically, we asked the agency to define ISPs’ offerings to edge providers – companies like Dropbox and Netflix that offer valuable services to Internet users – as a separate service. We explained why such a service would need to fall under “Title II” authority, and how in using that basis, the FCC can adopt effective and enforceable rules prohibiting blocking, discrimination, and paid prioritization online, to protect all users, both wired and wireless.

In addition to reiterating support for Title II remote delivery classification, today’s comments address some questions that arose about our initial proposal over the past two months, such as:

• How the Mozilla petition addresses interconnection,
• How forbearance would work,
• How the services we describe can be “services” without direct payment, and
• How the FCC can prohibit paid prioritization under Title II.

Our comments also articulate our views on net neutrality rules:

• A clean rule prohibiting blocking is the most workable and sustainable approach, rather than complex level of service standards;
• Prohibiting unreasonable discrimination is more effective than weaker alternatives such as “commercially unreasonable practices”;
• Paid prioritization inherently degrades the open Internet; and
• Mobile access services should have the same protections as fixed.

Mozilla will continue engaging closely with policymakers and stakeholders on this issue, and we encourage you to make your voice heard as well, before the next deadline for reply comments on September 10th. Here are some easy ways to contact the FCC and members of Congress and tell them to take the necessary steps to protect net neutrality and all Internet users and developers.

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