Internet2 Files Comments in the FCC’s Open Internet Proceeding

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By Matt Hall, Internet2 Senior Policy Advisor

On October 19, 2023, the Federal Communications Commission (FCC) launched a new proceeding on restoring open internet protections. The Notice of Proposed Rulemaking (NPRM) sought comment on classifying fixed and mobile broadband internet service as an essential “telecommunications” service under Title II of the Communications Act. 

The proposal also sought to restore clear, nationwide open internet rules that would prevent Internet Service Providers from blocking legal content, throttling speeds, and creating paid “fast lanes.” Enforcement of open internet protections for internet users was a commitment of the FCC from 2005 to 2018, and this proposal seeks to restore these protections. 

After consulting with its research and education (R&E) community partners, Internet2 decided to file comments in this proceeding on behalf of R&E networks.

R&E Community Committed to Open Networks

Internet2 and the R&E community are committed to the principle of network openness and recognize that increased connectivity between scientists, researchers, government, and community anchor institutions is fundamental to a free and educated society, both in theory and in practice. 

Our community’s commitment to open network principles has led to significant advancements in science, research, and education, as well as a history of continuous innovation that led to the invention of the internet itself. In the future, Internet2 and the R&E community will continue to operate according to open network principles.

Filed Comments Center on Scope, Refrainment From R&E Internet Exchange Regulation

In our filed comments, given the unique role of R&E networks, Internet2 urges the FCC to follow through on its current proposal to make clear that the scope of any rules adopted in this proceeding would not apply to private networks or specialized network arrangements, like those in place in the R&E community. Additionally, Internet2 requests that the FCC provide clear parameters about the scope of any final rules so that the R&E community is not adversely impacted by any unintended consequences stemming from the FCC’s efforts to protect consumers of mass-market retail broadband services. 

Internet2 further recommends that in addition to providing clear parameters about the scope of any final rules and given the highly specialized applications being enabled through Internet2’s network, the FCC should also continue to refrain from regulating internet traffic exchanges associated with R&E networks. Any other approach would open the door to the unintended consequences of preventing R&E network operators from taking actions that are in the best interest of research and education. 

Internet2 and its partners in the R&E community look forward to further engagement with the FCC as this proceeding moves forward.