To read the member company letter, click here.
To read the economic analysis mentioned in the filing, click here.
To read a two page summary of the economic analysis, click here.
Backs Existing Net Neutrality Rules
Internet Association filed its comments in the Federal Communications
Commission’s (FCC) “Restoring Internet Freedom” Notice of Proposed
Rulemaking (NPRM). Internet Association offered its full-throated
support for the 2015 Open Internet Order.
1.Both Quantitative And Qualitative Evidence Demonstrates The 2015 Open Internet Order Is Working. The Entire Internet Sector Is Thriving And There’s No Need To Change The Rules. •IA’s filing includes robust, statistically significant economic analysis that demonstrates ISP investment has not declined because of the current net neutrality rules. This quantitative evidence points in the same direction as the ordinary course statements from ISPs themselves since the current rules were enacted.
•From the filing: “There is no
reliable evidence that the 2015 Order has reduced ISPs’ investments in
broadband infrastructure. Comprehensive economic research by IA has
found that ISP investment is up over time, and shows no decline as a
result of the Commission’s 2015 Order…Multiple, independent metrics —
from actual capital expenditure numbers, to capacity, to prices —
demonstrate that ISP claims of depressed investment don’t mesh with
•From the filing: “Allowing paid
prioritization would in effect result in the ‘cable-ization’ of the
Internet, in which edge providers (like creators of video programming in
the cable context) would have to negotiate carriage deals on ISP
networks in order to reach consumers effectively. This would harm
startups and other small edge providers who lack the resources to pursue
and pay for prioritized carriage, and would place all edge providers at
the mercy of ISPs who would face minimal constraints on their ability to
charge edge providers for prioritized access. The ultimate losers would
be consumers who would be denied the wide variety of sources of content
and services from edge providers.”
•From the filing: “As the Commission
has explained previously, ISPs have clear economic incentives to favor
their own or affiliated content over third-party, edge provider content.
Whether by blocking, throttling, or otherwise discriminating against
third-party content, ISPs have the ability to negatively influence their
subscribers’ experience with third-party content and use their
gatekeeping power to favor their own or affiliated content, thereby
limiting consumer choice and competition.
•From the filing: “The NPRM’s failure
to address how its proposals will impact the cloud economy represents a
fundamental misunderstanding of innovation and investment in the
broadband economy and threatens to harm the largest driving force in the
U.S. economy today. The success of the cloud economy and the
transformation of the Internet into an indispensable part of daily life
is largely based on a free and open Internet, one that enables consumers
to access any website or app, buy any product, and use any service they