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Comment to FCC Commissioners on Open Internet

by Nicholas Barnard on July 15th, 2014

Dear FCC Commissioners,

An Open Internet is necessary for the the continued growth of our economy and more importantly for our democracy.

While the Internet to date has been in practice open, we are currently at a critical inflection point where Internet Service Providers, who themselves may also be content providers, are in a position where they can degrade the bandwidth available between independent content providers and those provider’s consumers.

Some content providers are hesitant to enter into situations where they are purchasing access to ISP’s networks. In the short term, this is a logical and appropriate move for content providers. However, in the long term this places content providers at the mercy of ISP’s rate increases, which may or may not be justified by the ISP’s costs.

I ask that the Commission reclassify Internet Service Providers from being Information Providers to being Telecommunication Service Providers. I also ask that the Commission promulgate rules that require that all ISPs provide:
a) connectivity to all active Autonomous Systems (AS) on the internet, such that, during peak times a website will load without timing out.
b) a tariffed, regulated, service that provides direct access to ISP routers that serve a several thousand customers. This service would would at minimum include a port for transmitting TCP/IP traffic to the ISP router as well as appropriate services provided by the ISP’s Network Operations Center. ISP’s should also be allowed to recoup a reasonable profit.
Item A would ensure that all the internet is accessible. Item Part B would allow content providers to provide improved service. By requiring a tariffed service, this ensures that costs in running an ISP are properly allocated, and as such are passed onto customers appropriately.

An Open Internet is critical for the success in may aspects of life of all Americans. I thank the commission for the opportunity to comment on this important issue.

Best Regards,
Nicholas Barnard

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