[178830] in North American Network Operators' Group

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Re: Verizon Policy Statement on Net Neutrality

daemon@ATHENA.MIT.EDU (Owen DeLong)
Tue Mar 10 21:55:01 2015

X-Original-To: nanog@nanog.org
From: Owen DeLong <owen@delong.com>
In-Reply-To: <D1245792.D7AA%Kelly.Setzer@wnco.com>
Date: Tue, 10 Mar 2015 18:51:51 -0700
To: Kelly Setzer <Kelly.Setzer@wnco.com>
Cc: "nanog@nanog.org" <nanog@nanog.org>
Errors-To: nanog-bounces@nanog.org


> On Mar 10, 2015, at 06:21 , Kelly Setzer <Kelly.Setzer@wnco.com> =
wrote:
>=20
> Many other organizations who were innovating will be affected by the =
new
> rules.  Many of those organizations are very small and cannot afford =
the
> army of lawyers that Verizon can.

Such as? Can you provide any actual examples of harmful effects or are =
you just ranting because you don=E2=80=99t like government involvement?

> And, no, I do not think recent regulatory efforts have been suitably
> cautious.  Enacting unpublished rules violates the spirit and history =
of
> open design, open discussion, and open standards that have made the
> Internet what it is today.

The rules are not unpublished, nor will they be unpublished when they =
are enacted. It=E2=80=99s true that the R&O isn=E2=80=99t out yet, but =
the actual rules (47CFR8) are published. Nothing takes effect until the =
R&O is published and due process is followed.

I can accept that there may not have been sufficient caution, but your =
claim that the current process violates the spirit and history of open =
design, open discussion, and open standards simply does not apply. The =
FCC followed the NPRM process and accepted a wide variety of public =
comment (and actually seems to have listened to the public comment in =
this case). As near as I can tell, they bent over backwards to be far =
more inclusive in the process than is historically normal in the FCC =
NPRM process.

I get that you don=E2=80=99t like the outcome, but I feel that your =
criticisms of the process reflect more of a lack of understanding of the =
normal federal rulemaking process than any substantive failure of that =
process.

Owen


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