2017 March

Statement On April ‘Infrastructure Month’ At FCC

Posted by | Broadband Internet | No Comments

Washington, DC, March 30, 2017 – Fred Campbell, director of Tech Knowledge, issued the following statement regarding FCC Chairman Ajit Pai’s announcement of proposals to encourage infrastructure deployment, which will be considered at next month’s FCC meeting:

“I’m pleased that Chairman Pai is moving so quickly to facilitate more public and private investment in next generation broadband infrastructure. His plan to lower utility pole costs and reduce red tape that’s holding up new networks will pave the way for faster broadband and 5G wireless deployments.

I also applaud the FCC’s plan to relax regulation for business data services where there is competition and preserve it where competition is lacking. That same competition-based approach to FCC regulation has served the public interest well for decades by encouraging investment while preventing anti-competitive practices and price increases, and I’m confident it will keep on serving the public interest under Chairman Pai’s watch.”

Tech Knowledge promotes market-oriented technology policies on behalf of the public interest. Additional information about Tech Knowledge can be found on our website, techknowledge.center.

Statement On Senate Resolution To Block FCC’s Discriminatory Privacy Rules

Posted by | Privacy, Regulatory State | No Comments

Washington, DC, March 23, 2017 – Fred Campbell, director of Tech Knowledge, issued the following statement regarding today’s Senate resolution to block the Federal Communications Commission from imposing discriminatory privacy rules on broadband internet service providers:

“The resolution enforces the enduring principle of equality in law—that the government must not impose rules that favor one class over another who is similarly situated. The FCC rules flouted this principle by singling out ISPs despite overwhelming evidence that other types of companies are similarly situated with respect to their ability to collect consumer data online.

Government coercion based on one’s membership in a particular class is the most corrupting of all, because it creates a government-sponsored privilege for the unregulated that cannot be explained by reference to first principles. When such regulation is accepted as legitimate, even for the best of pragmatic reasons, it corrodes the principles of justice that are necessary to support a free society. Left unchecked, discriminatory regulation will rust away those principles, and free society will fall.”

Tech Knowledge promotes market-oriented technology policies on behalf of the public interest. Additional information about Tech Knowledge can be found on our website, techknowledge.center.

Comments in Support of Petitions for Reconsideration

Posted by | Broadband Internet, Privacy | No Comments

Tech Knowledge filed the following comments in support of the petitions for reconsideration of the FCC’s broadband privacy rules (WC Docket No. 16-106).

Comments in Support of Petitions for Reconsideration

These comments illustrate the following points:

  1. Google’s decision to combine its users’ personally-identifiable information with the vast browsing data of its advertising subsidiary, DoubleClick, which accesses consumer data on 75.3% of all websites that use an ad server — a decision Google made after the submission of edge-provider data on which the FCC relied — renders the FCC’s finding inaccurate with respect to the percentage of web information Google can access.
  2. The FCC’s findings regarding encryption failed to consider consumers’ use of encrypted virtual private networks (VPNs) that are available at low cost and even for free. At a minimum, the FCC must explain why it’s necessary to impose unique privacy rules on ISPs when a solution is already widely-available in the marketplace at little or no cost.
  3. The FCC’s failure to consider the fact that its factual findings regarding edge providers directly contradict the factual findings made by the FTC — the federal agency who is the nation’s expert on edge provider regulation — constitutes arbitrary agency action as a matter of law.
  4. The FCC’s failure to consider arguments regarding the impact of its rules on competition among ISPs and edge providers in the online advertising and big data markets constitutes arbitrary agency action as a matter of law.
  5. Privacy is a personal right, and it’s reasonable for consumers to assume the law will protect their person from one network to another — but the FCC’s rules do not provide such protection.
  6. There is no legal barrier whatsoever to the FCC treating section 222 of the Communications Act as if it were coextensive with the FTC’s approach to privacy.

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Statement On FCC Action to Protect Consumers’ Online Privacy

Posted by | Privacy | No Comments

Washington, DC, March 1, 2017 – Fred Campbell, director of Tech Knowledge, issued the following statement regarding news that the Federal Communications Commission has taken action to provide consistent protection for American’s online privacy:

“I’m pleased to see that the FCC and FTC have pledged to work together on harmonizing the FCC’s privacy rules for broadband providers with the FTC’s standards for other online companies. Consumers will be best served by a consistent and easily understandable set of standards. Consumers’ privacy shouldn’t depend on which agency is charged with protecting it or the identity of the company that serves them. Consumers and internet companies alike deserve equal protection under the law.”

Tech Knowledge promotes market-oriented technology policies on behalf of the public interest. Additional information about Tech Knowledge can be found on our website, techknowledge.center.