LGBT Tech has submitted initial comments addressing the Federal Communications Commission’s (“FCC”) Notice of Proposed Rulemaking (“NPRM”) In the Matter of Restoring Internet Freedom.[1] The NPRM seeks public comment on how to preserve the basic principles of net neutrality and in its comments, LGBT Tech reiterates that the FCC needs to establish rules that apply equally to all participants in the broadband space.
The Internet has become an indispensable tool for members of the LGBT community offering connections and communication, and also access to education, health care information, and other vital resources. Over 50% of LGBT individuals use the Internet to meet new people and find others they can relate to. Further, surveys have shown that 81% of youth who identify as LGBT have used their connection to the Internet to search for health information compared to 46% of non-LGBT youth. Strong and fair rules that protect all consumers equally no matter what Internet site they happen to be surfing are essential for all consumers. Expanding access to broadband is crucial for our community and for many others, so we support smart policies that continue the approach that has worked so well for so long.
LGBT Tech has consistently believed, and continues to believe that the only way to ensure long-term legal consistency and prevent rule changes based on which way the political pendulum is currently swinging at the FCC is for Congress to reach across the aisle and pass common sense legislation that works for today’s dynamic digital networks. Clear bipartisan rules would have the benefit of providing certainty and stability for the further development of the open Internet. Furthermore, the broadband rules would no longer be subject to the varying political priorities inherent in the frequent changing of political appointees. Today more than ever, it’s crucial that the government enacts policies that strike the proper balance between encouraging the investment and competition that leads to expanded access to next-generation services and technologies and the privacy and access policies that ensure that communities like ours continue to enjoy the fruits of the broadband revolution. A comprehensive broadband bipartisan Congressional solution is essential to codifying and providing a stable environment where investment and innovation can thrive while safeguarding the open Internet policies needed to protect consumers. The fact remains that Congressional legislation has always been the best solution to provide the FCC with a roadmap to ensure an open and free Internet.
In addition, LGBT Tech has always supported and continues to support an Internet policy that ensures full and equal access for LGBT consumers and remains concerned that applying different standards to different participants in the Internet ecosystem will harm consumers. To this end, the FCC should reclassify ISPs under Title I where they can be regulated in the same manner as all other players in the Internet ecosystem including edge providers, thereby ensuring consistency and uniformity across the Internet ecosystem while ensuring that the bedrock principles of transparency, no blocking and no unreasonable discrimination are part of any FCC Internet policy. Imposing a Title II classification on ISPs is not the solution to protect net neutrality. Strapping an 80-year-old law to our current digital network is just putting a band-aid on the larger problem. Congress and the FCC should focus, rather, on creating rules and policies that are responsive to the current Internet environment and have been crafted specifically to address the modern problems we are facing.
The fact remains that Congressional legislation has always been the best solution to provide the FCC with a roadmap to ensure an open and free Internet.
The link for LGBT Tech’s FCC comments will be posted as soon as the comments appear on the FCC’s website.
[1] See In the Matter of Restoring Internet Freedom, Notice of Proposed Rulemaking, FCC 17-60, WC Docket No. 17-108 (Released May 23, 2017).