June 27, 2017
The Honorable Ajit Pai
Federal Communications Commission
445 12th Street SW
Washington, DC 20554
Dear Chairman Pai:
We write to inform you that as Internet Service Providers located across the country that we are
in full support of the current Open Internet Order and its underlying legal foundation under Title
II of the Communications Act. We have encountered no new additional barriers to investment or
deployment as a result of the 2015 decision to reclassify broadband as a telecommunications
service and have long supported network neutrality as a core principle for the deployment of
networks for the American public to access the Internet.
We wish to further express our opposition to the proposed plans to reverse course and again
undergo another reclassification of broadband back into an information service. The federal
courts have made it very clear that network neutrality depends on the FCC maintaining that
broadband is a telecommunications service and that other approaches have already failed as a
legal matter. We have always supported a neutral network approach to the Internet and see no
reason why it should not be required as a matter of law.
Without a legal foundation to address the anti-competitive practices of the largest players in the
market, the FCC’s current course threatens the viability of competitive entry and competitive
viability. As direct competitors to the biggest cable and telephone companies, we have
reservations about any plan at the FCC that seeks to enhance their market power without any
meaningful restraints on their ability to monopolize large swaths of the Internet.
Lastly, we implore the FCC to examine the ramifications of the Congressional Review Act
repeal of broadband privacy and provide guidance. We have long championed our customer’s
privacy and believe Congress was in error to erode their legal right to privacy. However, the
repeal’s detrimental impact on the reach and scope of Section 222’s ISP privacy provisions has
resulted in great uncertainty in the market that the FCC could help provide clarity.
A Better Wireless, NISP, LLC
Davis Community Network
DC Access, LLC
Digital Service Consultants
Enguity Technology Corp.
Full Channel Labs
Hubris Communications Inc.
Islesboro Broadband Committee
Mother Lode and Goldrush
Northwest Ohio Broadband
Public Access Networks Corp. (PANIX)
Router12 Networks LLC
Tekify Fiber & Wireless
Wilson Creek Communications