Federal Communications Commission
445 12th Street, SW
Washington D.C. 20554
Dear Chairman Wheeler and Commissioners:
This letter is written in response to your request for comments regarding proceeding 14-28.
I want a free and open Internet in the same context as our telephone system. By this I mean I want an infrastructure that is neutral as to sending and receiving parties and the content that they share. “Network neutrality” would be better framed as “non-discrimination” just as Verizon, for example, can’t privilege Verizon phone calls over T-Mobile’s or AT&T’s.
When a Verizon customer telephones an AT&T customer, the network treats the calls as though they were on the same network: call quality is not impaired when the incoming call is from a different network. And if I choose to use my phone to call 1-900 numbers, my telephone provider should have no say in that decision nor negatively impact my call quality.
This is how the Internet should work.
When I pay Frontier Communication for FiOS, Frontier should deliver all bits to my house that I seek out and do so without discrimination at the speed I’ve paid for service. If those bits are from Netflix they should be treated exactly the same as if they were from HBO or NBC or Apple or Amazon. They should not be choked or slowed down or interfered with in any way.
Our experience is that Frontier does this even though they say that they do not. Our AppleTV is hooked directly (via ethernet) to our Frontier regular router. It is not unusual for us to watch Netflix and discover that the video is painfully pixelated. When I switch to Netflix streamed wirelessly on my iPad, the pixelation disappears; so I use Apple’s mirroring technology to “throw” the video to my “TV” for viewing. Wifi, even at N speeds, should not trump a wired, ethernet connection.
This. Is. Wrong.
Moreover, Frontier should not be able to charge Apple or Amazon or Netflix for the privilege of sending video bits that I have paid for to my house. The content companies already pay their providers for the bandwidth that they use.
Telephone companies are regulated like common carriers. We need all infrastructure owners (cable, fiber, copper) to be considered common carriers. This would mean that they would have to lease their infrastructure to other organizations, and they would not be able discriminate based on the origin of a bit.
It would be helpful if the companies controlling the pipes into our homes weren’t also creating content that competes with other content providers. Why might Comcast want to degrade Netflix streaming? Because it competes with Comcast cable. This principle of fairness and equal access explains why 20th century regulators broke up Boeing and United Airlines, as well as why the U.S. Supreme Court made Paramount Pictures (et al) unbundle movie rentals and divest their movie theaters.
We have to separate content (the bits that represent text, photos, sound, moving pictures) from the delivery channel. That’s in part because we (society) can’t afford to have competing infrastructure: multiple “cable” or “fiber” wires on each-and-every neighborhood street. That sort of competition is economically inefficient: infrastructure is characterized by very high fixed costs and relatively low marginal costs (the cost of attaching the line to one-more-house).
And we have very next to no competition in broadband service. For example, Comcast is the dominant provider of “broadband” in 17 of our 20 largest metropolitan areas.
At my prior home in Bellevue, the choices are two:
Comcast – up to 25 MbPS, $40/month
CenturyLink – up to 7 MbPS, $30/month
At my current home in Lynnwood, the choices are two:
Comcast – up to 25 MbPS, $40/month
Frontier FiOS – up to 15 MbPS, $30/month
A duopoly does not competition make.
Consequently, the U.S. does not rank in the top 10 countries in the world based on average Internet connection speed (Akamai data from first quarter 2014).
If infrastructure ownership were decoupled from service, both should improve. As it stands, Americans pay more for less when it comes to Internet access and cellphone data plans than people in Europe and Japan. This situation will not change without government intervention.
The Internet is one of the most powerful communication tools that man has created. It brings information to the fingertips of those isolated from mammoth libraries. Do we really want that power to inform, educate and entertain go to the highest bidder?