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FCC Reply Comments regarding Preserving the Open Internet and Broadband Industry Practices

Submission Date: 

I. Introduction.

The American Cable Association ("ACA") files these Reply Comments in response to the Commission's Further Inquiry into Two Under-Developed Issues in the Open Internet Proceeding. It bears repeating that the impressive progress that ACA members have made in delivering broadband Internet services in a wide variety of lower density markets has been fostered by a regulatory environment characterized by "light touch" regulation. To preserve their ability to continue to do so, the Commission must keep foremost in mind that the costs and burdens of regulation can hinder broadband progress, especially for smaller providers. Accordingly, it is essential that "specialized" and "managed" services be exempt from any network neutrality regulation. Imposing unnecessary regulations on an ever growing array of Internet-based services will only constrain innovation and broadband investment. Broadband Internet service providers must also be permitted to use bandwidth or consumption-based billing models as a tool to address network congestion. These billing models should be deemed reasonable network management practices for all providers regardless of network technology - not just wireless providers. ACA urges the Commission to:

  • Exempt specialized and managed services from any regulation; and
  • Expressly recognize that bandwidth- or consumption-based billing models are reasonable network management practices for all broadband providers, not just wireless providers.

ACA highlights the ample support for ACA's proposals in the record below.


2010 11 04 Further Inquiry Open Internet Reply Comments FINAL (2).pdf132.91 KB

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