> Following the 2014 Notice and in the lead up to the Title II Order, Internet service providers stated that the increased regulatory burdens of Title II classification would lead to depressed investment.
To support this notion, they cite two reports that purport to show that capital expenditure by ISPs went down as a result of common carrier regulation.
The first [1] has data only from 2014 on, so has hardly any "before" data; and shows wild enough variability in the "after" data that it seems unreasonable to draw any conclusions from the average value over such a short time frame.
The second [2] is a convoluted enough statistical analysis that I'm not really able to evaluate it -- though it does appear to show that telecom investment in infrastructure appears to have grown at roughly the same rate as it had since the 1980s (save for some wild up and down swings prior to 2010) -- just not as fast as an invented "control group" of imaginary telecoms that never heard they might be classified as common carriers (see figure 3.)
That second link is extraordinary. They are claiming that
non-telecoms companies that have similar investment patterns to the telecoms industry before the Title II change can serve as a control.
That seems an awful lot like they're begging for a spurious correlation.
They might as well have generated a random walk that matched the investment levels.
ISPs, like all corporations, always have the best interests of their customers as heart. In the unlikely event that an ISP abuses their position another ISP startup will immediately spring up and start a brand new network.
Newspeak for sure. Can't speak out against it without being ostracized from the establishment. It worked with the Patriot Act, among countless others, so why would they stop?
They keep using terms like "Internet Freedom" or "Open Internet", but this isn't so much about the internet as it's about ISPs. They are the gatekeepers of the internet and Net Neutrality requires them to keep the gate open and free of obstacles.
At the very least, it will provide an easy way to share links to specific pages of the documents (of course, you can add notes and annotations to the pages, and there's been some rudimentary fact extraction done already).
I just loaded the document a moment ago, so I haven't had a chance to scan through and make sure all the details are correct, but wanted to share it so folks can scan through it now.
Feedback is definitely welcome, and I'll hold off on doing non-critical deploys today so it stays up while people read it. I've only been working on it for a few weeks so there's still quite a lot to do :)
Here is a draft of a comment I plan to submit to the FCC regarding this notice:
The draft seeks comment on the analysis in Paragraph 27. This analysis purports to show that broadband Internet service is an information service because it provides users the "capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information via telecommunications." The argument given is that broadband Internet service allows users to do all these things. However, this is not the same as providing the capability to do these things. To see why, consider that providing users Internet services over dialup phone lines also allows users to do all these things; but the phone lines themselves are telecommunications services, not information services. Why? Because providing the user dialup Internet, by itself, does not provide them the capability to do all these things. That capability is provided by the endpoints: the users' computers, and the computers hosting the Internet services that the users connect to.
Exactly the same is true of broadband Internet services provided by ISPs: by themselves, they do not provide users the capability to do all these things. They only provide connections between computers at the endpoints that provide those capabilities. It is the services provided by the Internet hosts that users connect to that are "information services". The broadband Internet services that allow users to connect to those hosts are telecommunications services, and should be regulated as such.
ISPs object to analyses like the one above because they claim that they also provide the actual information services--in other words, they also provide Internet hosts that function as email servers, web servers, etc. But it is obvious that those services are separate from the broadband connection services provided by those same ISPs, because users can make use of the latter without making use of the former at all. I am such a user: I use the broadband Internet connection provided by my ISP, but I do not use any of the information services they provide; I do not use their email, their web hosting, etc. I use other Internet hosts provided by other companies for those services. The fact that ISPs offer information services as well as telecommunications services does not make their telecommunications services into information services; an ISP's choice of business model cannot change the nature of a particular service it provides. Broadband Internet connections are obviously a telecommunications service, and should be regulated as such, regardless of what other services ISPs would like to bundle with them. The FCC should continue to regulate broadband Internet service as a telecommunications service.
Is it normal for these proposals to read like a plagiarized high school report?
They repeat "open internet" 43 times (disregarding the fact that the proposal is for quite the opposite) and copy-paste whole sections around the document, over and over again.
Although my data is very limited, I am beginning to suspect that quite a bit of new documentation produced by the current administration looks like high school work.
As admittedly minuscule evidence, I present the I-130 USCIS (was the INS) PDF form[1], which ballooned from 2 well-designed pages to a hideous 9 page effort, which has amateurish field validation and vast expanses of unfilled boxes into which one cannot even type "N/A" (because it's generally a bad idea to leave blank text fields on important forms)
The one question that I have is how do we stop this? Do I go somewhere to vote? Do I send a letter? Do I go to petition.org or something? Can I only donate to the EFF and that's it?
What do I need to do to have a concrete affect on the outcome of this instead of just commenting here or in some other thread?
What you can do now to stop a political process that ended last November is: nothing. It's in the past.
What you can do now to impact political processes in the near future (no policy is immutable, after all) is to work in your community to build consensus around policies you believe in, so that those policies are reflected in future decisions.
I don't know when, but at some point we as a country of citizens got really bad at understanding this, it seems like!
Vote and campaign in your next election for a candidate you believe in, send letters to your representatives to not vote for anti-net-neutrality legislation, and donate to the EFF.
The petition.org thing is useless.
Like the other poster said, though, these are the consequences of last novembers election. You won't undo what is happening now. You can just participate to stop it from happening again and reverse the course to the best of your ability in the future.
From page 3, on the regulation of ISPs as utilities:
...the order has weakened Americans’ online privacy by stripping the Federal Trade Commission — the nation’s premier consumer protection agency — of its jurisdiction over ISPs’ privacy and data security practices.
That's pretty rich, coming from the government that just overturned an Obama-era privacy ruling.
$99/month Family Freedom package:
- 200GB "Streaming Gigs" for up to four authorized devices
- 100GB "Gaming Gigs" (with Super-Ping technology!)
- 25GB "Other"
- Unlimited email, Facebook and Snapchat!
Little glimpse in to our future, ladies and gents.
There's a giveaway in my opinion in the length the NPRM goes to in questioning the necessity of the existing rules, and the small space afforded to providing a legal basis for enforcing them should Title II authority be revoked as proposed.
The idea seems to be: if the rules themselves (no throttling, no paid prioritization etc) are not necessary (i.e. voluntary), neither is a legal framework to support them.
So statements that net neutrality is not under fire here, only the current legal basis for it, sound pretty hollow in my opinion. By failing to provide an alternative authority to support the existing rules, they're sentencing them to unenforceability and effective repeal. (edit: grammar)
This seems to be a common theme in this administration to "restore freedoms" to corporations with bald-faced lies that they restore freedoms to individuals. The current rhetoric surrounding the recent order to review many national monuments is steeped in very similar twisted logic - that somehow the land needs to be "returned to the people". But wait, wasn't that national monument set aside exactly for preserving a small chunk of pristine wilderness for "the people"?
I don't think I can put up with 4 more years of these bozos.
Since I'm a nice, law-abiding citizen, I can only suggest further unearthing and bringing into the light of day all the sleaze in these people's backgrounds and getting them disqualified and removed from office.
The 2008 financial crisis should have ended a lot of sleazy careers. Instead, here we are.
There are good people on both the "liberal/progressive/whatever" side of the arbitrary political fence, and on the "small-c-conservative/values/whatever" side.
Only, we don't want war. We want reasonably rational and emotionally mature discussion and the ability to get along and get things done. And enough trust in good intentions to invest in a variety of plans and figure out and measure what actually works.
And... it'd be nice to have an open network left to do this on. For a reasonable price.
P.S. Sorry for my "outburst." Just, exhausted with this whack-a-mole against moneyed self-interests that can afford to just keep trying again and again and again until they get their way.
Because, they aren't about creating the most (absolute) value. Just capturing the most (relative) value, for themselves.
"Restoring Internet Freedom" It reminds me of some Newspeak the government in 1984 would say. Just blatantly saying the opposite of what they are doing like that will make it true.
No, you are the one who has redefined freedom. Freedom originally meant that you could deal with whoever you wanted on whatever terms both parties could agree on. It didn't mean the government regulating private businesses to ensure some specific outcome.
I understand why HN wants net neutrality: the majority here think that ISPs have undeserved control, and so the government needs to step in to ensure a level playing field. Still, if someone advocated "search engine neutrality", arguing that the govt should regulate Google's search results to ensure everyone had a fair chance, there would be uproar. Similarly, if someone argued for "platform neutrality", holding that every startup that offered some kind of API had to register with the gov't to ensure their services were equally available to all others, the insanity would be obvious.
Freedom as another word for 'regulating to death'. I feel so free in modern society, as the body of law grows day by day, already being a completely incomprehensible mess that no human (or company) can abide by.
EDIT: Also, before you downvote, please try to find a fault in the following statement: 'as the body of law grows day by day, already being a completely incomprehensible mess that no human (or company) can abide by.' If you can, please post why. If you cannot, please go back to pondering about this.
> In contrast, Internet service providers do not appear to offer “telecommunications,” i.e.,
“the transmission, between or among points specified by the user, of information of the user’s choosing,
without change in the form or content of the information as sent and received,” to their users. For one,
broadband Internet users do not typically specify the “points” between and among which information is
sent online. Instead, routing decisions are based on the architecture of the network, not on consumers’
instructions, and consumers are often unaware of where online content is stored. Domain names must be
translated into IP addresses (and there is no one-to-one correspondence between the two). Even IP
addresses may not specify where information is transmitted to or from because caching servers store and
serve popular information to reduce network loads.
This is absurd. Under this logic, telephones "do not offer 'telecommunications'":
* Telephone users never specify the 'specify the “points” between and among which information is
sent'. When I call a particular phone number, I can't choose which cell towers are used, or what internal routing is used to connect my call.
* Users are often unaware of 'where [content] is stored'. When I place a call, I don't know if I'm calling a SIP phone, landline, cell phone, or something else entirely.
* If the existence of DNS means that the ISPs don't provide 'telecommunications', then the existence of phone directory services (e.g. Version 411) should mean that telephone companies also don't provide 'telecommunications'.
* IP addresses are logical address, not physical addresses. Neither phone numbers nor IP dresses specify exactly where information will end up - a call could be handled by a phone company-provided voicemail service, or redirected to another phone entirely.
It gets worse. From the same page:
> For another, Internet service providers routinely change the form or content of the
information sent over their networks—for example, by using firewalls to block harmful content or using
protocol processing to interweave IPv4 networks with IPv6 networks
Again, all of those items are analagous (no pun intended) to similar parts of telephone networks. Phone companies can block calls by scammers (e.g. http://fortune.com/2017/03/24/how-t-mobile-plans-to-block-ph...), and can change the encoding and encapsulation of the call audio as many times as they want to.
These are good points; do you mind if I add them to the draft comment I am preparing (which I've posted--in two installments--in this discussion thread)?
Interesting wording in that paragraph too. The quoted extract says "the transmission, between OR among points" yet the following sentence refers to ""points" between AND among." That subtle change allows them to argue that the Internet isn't a telecommunications system because users don't explicitly specify ALL the points along a route. Gross.
To whom it may concern at the FCC, As the head of an ISP I must tell you that I am entirely dissatisfied with the billions of dollars I make providing a mediocre utility service with near zero competition to customers who pay for that service. I see the billions of dollars being made by Facebook and Google through innovation and user consent and I want to take that money with political and regulatory force. I'll need you to first make it entirely legal for me to capture and sell all data about my users. Not because they consent, not because they want this but because I want a new cash cow to slaughter. I'm going to use this information to become an alternative provider of targeted ads to my customers. Next, I'll need you to allow me to throttle back the speed by which customers can access my competitors services because mine aren't as good. This isn't so much a toll road as a team of aggressive traffic cops, pulling over any business making too much money on my big dumb pipe to slow them down... fine them and then let them slowly attempt to carry on. I need this all because I don't innovate, I don't like my customers or give a shit what they want. I am simply used to using raw power and corrupt regulatory force to act as a parasite extracting the maximum tariff from productive businesses, people and entrepreneurs possible while keeping some of my hosts alive... but killing the smaller ones. I am big business. I am angry because I am losing. The actual free and open internet is allowing actual free market capitalism and user choice in too many things. I used to fight this kind of thing in back rooms quietly but this fight has escalated so now I must come out in the open and ask the government publicly to please take from the poor and give to me in new ways... because the poor keep innovating their way out of the traps I set. Finally, I disrespectfully request that the rules I propose be named the exact opposite of what they stand for, so it's clear this isn't a discussion with reasonable people but a raw show of force. -Old Rich Guy
The funny thing is that this will likely lead to a lot more significant losses in online privacy. The ISPs will now extort money from Google/YouTube, Netflix, Facebook, and Amazon...at least two of whom will need to track users more in order to better target ads (since they're already at max-ad-display thresholds) to increase ad yields. So to generate more revenues to feed ISP extortion, it's likely to drive companies to track you further.
[+] [-] outsidetheparty|9 years ago|reply
> Following the 2014 Notice and in the lead up to the Title II Order, Internet service providers stated that the increased regulatory burdens of Title II classification would lead to depressed investment.
To support this notion, they cite two reports that purport to show that capital expenditure by ISPs went down as a result of common carrier regulation.
The first [1] has data only from 2014 on, so has hardly any "before" data; and shows wild enough variability in the "after" data that it seems unreasonable to draw any conclusions from the average value over such a short time frame.
The second [2] is a convoluted enough statistical analysis that I'm not really able to evaluate it -- though it does appear to show that telecom investment in infrastructure appears to have grown at roughly the same rate as it had since the 1980s (save for some wild up and down swings prior to 2010) -- just not as fast as an invented "control group" of imaginary telecoms that never heard they might be classified as common carriers (see figure 3.)
That's shady, right? It sure seems shady.
[1] https://haljsinger.wordpress.com/2017/03/01/2016-broadband-c...
[2] http://www.phoenix-center.org/perspectives/Perspective17-02F...
[+] [-] bovine3dom|9 years ago|reply
That seems an awful lot like they're begging for a spurious correlation.
They might as well have generated a random walk that matched the investment levels.
[+] [-] ComradeTaco|9 years ago|reply
[+] [-] jacquesm|9 years ago|reply
[+] [-] bb88|9 years ago|reply
[+] [-] ikeyany|9 years ago|reply
[+] [-] archgoon|9 years ago|reply
[+] [-] wheelerwj|9 years ago|reply
[+] [-] jarcoal|9 years ago|reply
[+] [-] icey|9 years ago|reply
At the very least, it will provide an easy way to share links to specific pages of the documents (of course, you can add notes and annotations to the pages, and there's been some rudimentary fact extraction done already).
I just loaded the document a moment ago, so I haven't had a chance to scan through and make sure all the details are correct, but wanted to share it so folks can scan through it now.
Feedback is definitely welcome, and I'll hold off on doing non-critical deploys today so it stays up while people read it. I've only been working on it for a few weeks so there's still quite a lot to do :)
[+] [-] givinguflac|9 years ago|reply
[+] [-] appleflaxen|9 years ago|reply
[+] [-] pdonis|9 years ago|reply
The draft seeks comment on the analysis in Paragraph 27. This analysis purports to show that broadband Internet service is an information service because it provides users the "capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information via telecommunications." The argument given is that broadband Internet service allows users to do all these things. However, this is not the same as providing the capability to do these things. To see why, consider that providing users Internet services over dialup phone lines also allows users to do all these things; but the phone lines themselves are telecommunications services, not information services. Why? Because providing the user dialup Internet, by itself, does not provide them the capability to do all these things. That capability is provided by the endpoints: the users' computers, and the computers hosting the Internet services that the users connect to.
Exactly the same is true of broadband Internet services provided by ISPs: by themselves, they do not provide users the capability to do all these things. They only provide connections between computers at the endpoints that provide those capabilities. It is the services provided by the Internet hosts that users connect to that are "information services". The broadband Internet services that allow users to connect to those hosts are telecommunications services, and should be regulated as such.
ISPs object to analyses like the one above because they claim that they also provide the actual information services--in other words, they also provide Internet hosts that function as email servers, web servers, etc. But it is obvious that those services are separate from the broadband connection services provided by those same ISPs, because users can make use of the latter without making use of the former at all. I am such a user: I use the broadband Internet connection provided by my ISP, but I do not use any of the information services they provide; I do not use their email, their web hosting, etc. I use other Internet hosts provided by other companies for those services. The fact that ISPs offer information services as well as telecommunications services does not make their telecommunications services into information services; an ISP's choice of business model cannot change the nature of a particular service it provides. Broadband Internet connections are obviously a telecommunications service, and should be regulated as such, regardless of what other services ISPs would like to bundle with them. The FCC should continue to regulate broadband Internet service as a telecommunications service.
[+] [-] pdelbarba|9 years ago|reply
They repeat "open internet" 43 times (disregarding the fact that the proposal is for quite the opposite) and copy-paste whole sections around the document, over and over again.
[+] [-] idbehold|9 years ago|reply
[+] [-] QuinnyPig|9 years ago|reply
[+] [-] sinak|9 years ago|reply
[+] [-] defined|9 years ago|reply
As admittedly minuscule evidence, I present the I-130 USCIS (was the INS) PDF form[1], which ballooned from 2 well-designed pages to a hideous 9 page effort, which has amateurish field validation and vast expanses of unfilled boxes into which one cannot even type "N/A" (because it's generally a bad idea to leave blank text fields on important forms)
[1]: https://www.uscis.gov/sites/default/files/files/form/i-130.p...
[+] [-] drenvuk|9 years ago|reply
What do I need to do to have a concrete affect on the outcome of this instead of just commenting here or in some other thread?
[+] [-] loteck|9 years ago|reply
What you can do now to impact political processes in the near future (no policy is immutable, after all) is to work in your community to build consensus around policies you believe in, so that those policies are reflected in future decisions.
I don't know when, but at some point we as a country of citizens got really bad at understanding this, it seems like!
[+] [-] zanny|9 years ago|reply
The petition.org thing is useless.
Like the other poster said, though, these are the consequences of last novembers election. You won't undo what is happening now. You can just participate to stop it from happening again and reverse the course to the best of your ability in the future.
[+] [-] ShannonAlther|9 years ago|reply
...the order has weakened Americans’ online privacy by stripping the Federal Trade Commission — the nation’s premier consumer protection agency — of its jurisdiction over ISPs’ privacy and data security practices.
That's pretty rich, coming from the government that just overturned an Obama-era privacy ruling.
[+] [-] overcooked|9 years ago|reply
[deleted]
[+] [-] mundo|9 years ago|reply
[+] [-] devindotcom|9 years ago|reply
The idea seems to be: if the rules themselves (no throttling, no paid prioritization etc) are not necessary (i.e. voluntary), neither is a legal framework to support them.
So statements that net neutrality is not under fire here, only the current legal basis for it, sound pretty hollow in my opinion. By failing to provide an alternative authority to support the existing rules, they're sentencing them to unenforceability and effective repeal. (edit: grammar)
[+] [-] glitcher|9 years ago|reply
[+] [-] pasbesoin|9 years ago|reply
Since I'm a nice, law-abiding citizen, I can only suggest further unearthing and bringing into the light of day all the sleaze in these people's backgrounds and getting them disqualified and removed from office.
The 2008 financial crisis should have ended a lot of sleazy careers. Instead, here we are.
There are good people on both the "liberal/progressive/whatever" side of the arbitrary political fence, and on the "small-c-conservative/values/whatever" side.
It's the sleaze. On whatever side.
Arrogant sleaze. Slime-y sleaze. Delusional sleaze. Psycho-/Socio-pathic sleaze.
Time for the War on Sleaze.
Only, we don't want war. We want reasonably rational and emotionally mature discussion and the ability to get along and get things done. And enough trust in good intentions to invest in a variety of plans and figure out and measure what actually works.
And... it'd be nice to have an open network left to do this on. For a reasonable price.
P.S. Sorry for my "outburst." Just, exhausted with this whack-a-mole against moneyed self-interests that can afford to just keep trying again and again and again until they get their way.
Because, they aren't about creating the most (absolute) value. Just capturing the most (relative) value, for themselves.
[+] [-] quadrangle|9 years ago|reply
Unfortunately, there really are enough laws that everyone is constantly breaking some. Selective enforcement can be used to shut up critics…
[+] [-] sinak|9 years ago|reply
Just click "New Filing" or "New Express" depending on what kind of comment you want to leave.
We just submitted comments here in case you need ideas: https://ecfsapi.fcc.gov/file/DOC-56ec3d08ba000000-A.pdf
[+] [-] JohnJamesRambo|9 years ago|reply
War is Peace
Freedom is Slavery
Ignorance is Strength
[+] [-] objectivistbrit|9 years ago|reply
I understand why HN wants net neutrality: the majority here think that ISPs have undeserved control, and so the government needs to step in to ensure a level playing field. Still, if someone advocated "search engine neutrality", arguing that the govt should regulate Google's search results to ensure everyone had a fair chance, there would be uproar. Similarly, if someone argued for "platform neutrality", holding that every startup that offered some kind of API had to register with the gov't to ensure their services were equally available to all others, the insanity would be obvious.
[+] [-] Kenji|9 years ago|reply
EDIT: Also, before you downvote, please try to find a fault in the following statement: 'as the body of law grows day by day, already being a completely incomprehensible mess that no human (or company) can abide by.' If you can, please post why. If you cannot, please go back to pondering about this.
[+] [-] Aaron1011|9 years ago|reply
> In contrast, Internet service providers do not appear to offer “telecommunications,” i.e., “the transmission, between or among points specified by the user, of information of the user’s choosing, without change in the form or content of the information as sent and received,” to their users. For one, broadband Internet users do not typically specify the “points” between and among which information is sent online. Instead, routing decisions are based on the architecture of the network, not on consumers’ instructions, and consumers are often unaware of where online content is stored. Domain names must be translated into IP addresses (and there is no one-to-one correspondence between the two). Even IP addresses may not specify where information is transmitted to or from because caching servers store and serve popular information to reduce network loads.
This is absurd. Under this logic, telephones "do not offer 'telecommunications'":
* Telephone users never specify the 'specify the “points” between and among which information is sent'. When I call a particular phone number, I can't choose which cell towers are used, or what internal routing is used to connect my call.
* Users are often unaware of 'where [content] is stored'. When I place a call, I don't know if I'm calling a SIP phone, landline, cell phone, or something else entirely.
* If the existence of DNS means that the ISPs don't provide 'telecommunications', then the existence of phone directory services (e.g. Version 411) should mean that telephone companies also don't provide 'telecommunications'.
* IP addresses are logical address, not physical addresses. Neither phone numbers nor IP dresses specify exactly where information will end up - a call could be handled by a phone company-provided voicemail service, or redirected to another phone entirely.
It gets worse. From the same page:
> For another, Internet service providers routinely change the form or content of the information sent over their networks—for example, by using firewalls to block harmful content or using protocol processing to interweave IPv4 networks with IPv6 networks
Again, all of those items are analagous (no pun intended) to similar parts of telephone networks. Phone companies can block calls by scammers (e.g. http://fortune.com/2017/03/24/how-t-mobile-plans-to-block-ph...), and can change the encoding and encapsulation of the call audio as many times as they want to.
[+] [-] pdonis|9 years ago|reply
[+] [-] pdelbarba|9 years ago|reply
[+] [-] theclaw|9 years ago|reply
[+] [-] Sephr|9 years ago|reply
It's a disgustingly disingenuous billboard near the FCC headquarters that is being seen by many FCC employees on their commute to work.
[+] [-] outsidetheparty|9 years ago|reply
[+] [-] ethics_gradient|9 years ago|reply
[+] [-] thomastjeffery|9 years ago|reply
[+] [-] djyaz1200|9 years ago|reply
[+] [-] theprop|9 years ago|reply
[+] [-] shmerl|9 years ago|reply
Hypocrites.
[+] [-] donatj|9 years ago|reply
[+] [-] unknown|9 years ago|reply
[deleted]