FCC Reply Comments on Net Neutrality

Today is the final deadline to file comments as part of the Federal Communications Commission’s open proceeding on net neutrality in the United States. The show of support for real net neutrality over the past six months has been tremendous – so much so that this issue has now received more public comments than any other in FCC history, nearly 1.5 million in total.

Mozilla has been pulling out all the stops as well. In May, we submitted an original petition to the FCC to propose a new path forward on the difficult question of authority, and to shake up a debate that had not seen many new ideas. We’ve also launched global teach-ins, filed comments, and joined last week’s Day of Action, among other activities.

Our reply comments filed today build on these past actions, summarize the state of the debate, and respond to net neutrality opponents. Our comments are structured around four points:

1. Most parties agree on most issues. The FCC should adopt enforceable rules, including some form of a no blocking and no unreasonable discrimination rule, with an exception for reasonable network management.
2. Mozilla’s classification theory is a viable and strong path forward. Mozilla’s approach ensures real net neutrality while bypassing the political conversation over reclassification, by articulating a new, not yet classified Title II service offered to remote end points.
3. The FCC must adopt a presumption against paid prioritization. Allowing prioritization would degrade other uses of the Internet, and thus cause harm to user choice, innovation, and competition.
4. The same rules should apply to mobile and fixed services. There is one Internet and it must remain open for all. Technical requirements for mobile networks can be protected through reasonable network management.

This week, the FCC will conduct roundtables on net neutrality, with varying focuses including technical, legal, and enforcement aspects. I’ll be participating in one of the Friday sessions, focusing on the topic of enforcement. The roundtables will be held in DC, and will include a moderated discussion among a diversity of viewpoints. At this stage of the process, I don’t expect much in the way of agreement – but at least a range of options will be presented and defended for the agency’s consideration. The public has been invited to submit questions in advance over email or Twitter – roundtables@fcc.gov or #FCCRoundtables – though a caveat from the session description: Your questions and identifying information will be made public and included in the official record.

We’ve seen comments, petitions, roundtables, protests, and events for months now. The main thing left is for the agency to make some decisions – and as we note in our comments, the outcome will set the course for the future of the industry, for better or for worse.

There’s still time for you to make your voice heard. You can contact the FCC and members of Congress, and ask them to protect net neutrality, and the choice, innovation, and freedom enjoyed today by all Internet users and developers.