The Institute for Local Self-Reliance recently submitted comments to the FCC as part of its Protecting and Promoting the Open Internet proceeding. ILSR focused on the issue of paid prioritization, reclassification, and regulation of content. We also provided some examples of municipal networks that provide fast, reliable, affordable service and do not rely on paid prioritization to serve customers.

From the ILSR comments:

The FCC should be extremely wary of any arguments that claim paid prioritization or other discriminatory practices are necessary to increase investment in next-generation networks. These networks are already being built and paying for themselves in both public and private approaches (as well as partnerships mixing the two). ILSR sees no reason to believe any additional revenues gained by discriminatory pricing would be reinvested in improving DSL and cable networks as the largest firms operating these networks generally face little competitive pressure to upgrade. That is the problem, not a lack of revenue in the current model.

Our reading of the various court decisions suggest the only option for the FCC to preserve the open Internet and prevent big cable and telephone companies from tinkering with the established principle of non-discriminatory carriage is reclassification and urge the FCC to take this step. However, we also urge the FCC to take actions to prevent any regulation of content. The FCC should concern itself with the transmission of information, regardless of what that information is, consistent with long-held Internet principles.

The Open Internet proceeding has inspired an estimated 1 million+ comments. The outpouring strained the FCC's system and as a result, the FCC extended the comment period to July 18th.

The full document is available below for download and available on the FCC's electronic filing system.

a. Governments have engaged in various initiatives to increase broadband deployment and adoption in certain geographic areas. With regard to specific examples of federal, state, tribal, or local broadband initiatives, how did the initiatives come to fruition from start to finish? Please describe cost information, including planning, equipment, training, labor, and conclusion of the initiatives, as well as barriers that were overcome. What elements of the initiation, planning, or implementation were most critical to the success of the project? What factors impacted the technological choices made in the planning and implementation of the project? Were the projects sustainable, and have the projects continued beyond their initially conceived timeframes? What were the costs and the resulting empirically demonstrable benefits or harms of the implementation? How did costs and benefits differ from the original plan and why? b. What conclusions should be drawn from any particular experiences (e.g., what efforts or practices should be replicated or avoided)? c. Please provide examples of governments aggregating demand to encourage broadband deployment. Are such programs sustainable? Do these programs cause the deployment of network infrastructure that otherwise would not have occurred? Please provide data when possible. d. How can successful broadband solutions be more widely shared or publicized to enable other governments to benefit? What should be the role for the federal government (and specifically, this Commission) in fostering the widespread adoption of ideas and initiatives that have worked? e.

a. Governments have engaged in various initiatives to increase broadband deployment and adoption in certain geographic areas. With regard to specific examples of federal, state, tribal, or local broadband initiatives, how did the initiatives come to fruition from start to finish? Please describe cost information, including planning, equipment, training, labor, and conclusion of the initiatives, as well as barriers that were overcome. What elements of the initiation, planning, or implementation were most critical to the success of the project? What factors impacted the technological choices made in the planning and implementation of the project? Were the projects sustainable, and have the projects continued beyond their initially conceived timeframes? What were the costs and the resulting empirically demonstrable benefits or harms of the implementation? How did costs and benefits differ from the original plan and why? b. What conclusions should be drawn from any particular experiences (e.g., what efforts or practices should be replicated or avoided)? c. Please provide examples of governments aggregating demand to encourage broadband deployment. Are such programs sustainable? Do these programs cause the deployment of network infrastructure that otherwise would not have occurred? Please provide data when possible. d. How can successful broadband solutions be more widely shared or publicized to enable other governments to benefit? What should be the role for the federal government (and specifically, this Commission) in fostering the widespread adoption of ideas and initiatives that have worked? e.

a. Governments have engaged in various initiatives to increase broadband deployment and adoption in certain geographic areas. With regard to specific examples of federal, state, tribal, or local broadband initiatives, how did the initiatives come to fruition from start to finish? Please describe cost information, including planning, equipment, training, labor, and conclusion of the initiatives, as well as barriers that were overcome. What elements of the initiation, planning, or implementation were most critical to the success of the project? What factors impacted the technological choices made in the planning and implementation of the project? Were the projects sustainable, and have the projects continued beyond their initially conceived timeframes? What were the costs and the resulting empirically demonstrable benefits or harms of the implementation? How did costs and benefits differ from the original plan and why? b. What conclusions should be drawn from any particular experiences (e.g., what efforts or practices should be replicated or avoided)? c. Please provide examples of governments aggregating demand to encourage broadband deployment. Are such programs sustainable? Do these programs cause the deployment of network infrastructure that otherwise would not have occurred? Please provide data when possible. d. How can successful broadband solutions be more widely shared or publicized to enable other governments to benefit? What should be the role for the federal government (and specifically, this Commission) in fostering the widespread adoption of ideas and initiatives that have worked? e.