Abstract
On August 30, 2017, a coalition of higher education leadership associations, including EDUCAUSE, submitted reply comments to the Federal Communications Commission (FCC) about its 2017 network neutrality rule-making. (The reply comment period of an FCC rule-making gives respondents a chance to review points raised by others during the initial comment period and clarify or extend their arguments as a result.) The coalition built on in its July 17, 2017, analysis and recommendations by highlighting support in the record for preserving the existing 2015 network neutrality rules or, should the FCC overturn those, establishing strong, enforceable network neutrality protections under Section 706 of the Telecommunications Act. The coalition also pushed back against arguments that transparency requirements or antitrust protections could or would adequately preserve network neutrality.