Abstract
On July 18, 2014, EDUCAUSE joined with other leading higher education and library organizations to submit formal comments in response to the 2014 Federal Communications Commission (FCC) NPRM entitled, “Protecting and Promoting the Open Internet” (GN Docket No. 14-28). Building on the network neutrality principles these organizations and others had previously submitted, the comments urged the FCC to incorporate the needs of higher education and libraries into its proposed open Internet rules by:
- Clarifying that the proposed rules encompass commercial broadband Internet access service provided to libraries and higher education institutions;
- Prohibiting “paid prioritization”;
- Ensuring that the proposed rules are technology-neutral and apply to both fixed and mobile services;
- Adopting a redefined “no-blocking” rule that bars public broadband Internet access providers from interfering with the user’s choice of content, applications, or services;
- Strengthening disclosure rules;
- Charging the proposed ombudsman with protecting the interests of libraries and higher education institutions, in addition to consumers and small businesses;
- Recognizing that libraries and institutions of higher education operate private networks or engage in end-user activities that are not subject to open Internet rules; and
- Exercising one or more of its well-established sources of authority (e.g., Section 706 of the Telecommunications Act, utilizing an “Internet reasonable” standard) to implement rules that preserve the unique capacities of the Internet as an open platform.