NTCA Comments on Net Neutrality Proposal

NTCA submits that overriding public interest goals can be accomplished with narrowly drawn measures that focus upon key potential points of failure in the transmission of content and data, regardless of where they reside in the ecosystem. And, where intervention is warranted, NTCA submits that a “light touch” approach using regulatory backstops in lieu of the imposition of substantial ex ante regulation on only one segment will be best suited to the continuing advancement and evolution of the marketplace—and critical to avoid deterring last-mile network investment and burdening smaller rural ISPs who themselves are critical to a vision of universal connectivity. NTCA further submits that, if the proposed actions should proceed notwithstanding these perspectives, the Federal Communications Commission need not impose additional measures to safeguard national security, consumer protection, or privacy. Finally, should the FCC nonetheless proceed with reclassification, it should not forbear from universal service contribution obligations under Section 254 of the Communications Act, as amended, because this would be contrary to the public interest, undermine public policy objectives that the FCC otherwise identifies as important in other contexts, and harm consumers by failing to carry out faithfully statutory mandates with respect to support of universal service.