2014 FCC Net Neutrality Rule-Making: Higher Education/Libraries Reply Comments

Abstract

In July 2014, a coalition of higher education and library groups, including EDUCAUSE, submitted formal comments to the Federal Communications Commission (FCC) regarding its “open Internet” (network neutrality) notice of proposed rule-making. As part of the rule-making process, the FCC also accepted comments through early September that were submitted in response to the initial July filings it had received. EDUCAUSE again joined with other higher education and library organizations to provide such “reply comments,” which focused on further explaining how the FCC might best reestablish strong network neutrality rules utilizing its legal authority under Section 706 of the Telecommunications Act.

In particular, the higher education/libraries reply comments:

1. Provided additional examples of the importance of an open Internet for education, research, and learning;
2. Clarified the proposal to establish a no-blocking rule that requires an ISP to fulfill the consumer’s decision to access whatever applications, services, or web sites s/he chooses once the ISP has chosen to provide Internet access to him or her;
3. Elaborated on the proposal that the FCC should adopt an “Internet reasonable” standard (rather than a “commercially reasonable” standard) under Section 706; and
4. Reiterated that the proposed rules should not apply to end-user or private networks, such as campus or library networks, or private networks that serve campuses or libraries.