One of the biggest obstacles to overcome is authority, and how to get past limitations put into law several years ago. Our petition tackles this challenge head-on:
- Last-mile, terminating access Internet routing is currently understood to include one type of commercial relationship: between an ISP (Comcast, in the sample image) and an end user (Carol, in the image), connecting the end user to all Internet sites. We are challenging that understanding and proposing a modernization.
- We ask the FCC to recognize that technological evolution has led to two distinct relationships in the last mile of the network: the current one, between an ISP and an end user, which is unchanged, plus a “remote delivery” service offered by an ISP to an edge provider (Dropbox, in the image), connecting the provider to all of the ISP’s end users.
- In the key to our argument, we then ask the FCC to designate remote delivery services as telecommunications services under Title II of the Communications Act.
Categorizing remote delivery services as telecommunications services is consistent with the guidelines set by both Congress and the DC Circuit Court of Appeals, and would give the FCC ample ability to adopt and enforce meaningful net neutrality. With clear authority and effective rules, ISPs would be prevented from blocking or discriminating against any edge provider, whether on a wireline or wireless network.