USTelecom: Benefits of Title 1 Outweigh Purported Costs

Urges FCC to stay deregulatory course
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USTelecom told the FCC this week it supports a free and open Internet, just one defined as "unencumbered by unnecessary regulations." 

It was filing reply comments in a court remand of portions of the FCC's 2018 Restoring Internet Freedom order, most of which the court upheld. 

Related: NCTA Says Record Supports FCC Net Neutrality Dereg 

The court asked the FCC to better explain why it had concluded that reclassifying internet access as an information service not subject to common carrier mandatory access rules and eliminating the rules against blocking, throttling and paid prioritization did not harm public safety, pole attachments or the FCC's low income broadband subsidies. 

USTelecom said the RIF order benefitted public safety and did not undermine either the pole attachment regulatory framework or the Lifeline broadband subsidy. 

As have other ISP commenters, USTelecom pointed to the increased investment prompted by the deregulation as benefitting first responders generally and the consumers "who rely on such infrastructure to generate and receive important public-safety communications." 

Those who have suggested there could be some negative impact on public safety are generally referring to the ability to block or throttle if that affected first responder communications. 

But in its final analysis, USTelecom says the record clearly demonstrates that "the overwhelming benefits of the restored Title I classification vastly outweigh the purported costs (if any) of abandoning the outdated, common carrier regulatory framework applicable to broadband for the scant two years preceding the RIF Order." 

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