Hearing #1 On Competition and Consumer Protection in the 21st Century - Sept. 13-14 at Georgetown University Law Center #FTC-2018-0074-D-0008

Submission Number:
FTC-2018-0074-D-0008
Commenter:
CJ Ng
State:
New York
Initiative Name:
Hearing #1 On Competition and Consumer Protection in the 21st Century - Sept. 13-14 at Georgetown University Law Center
Since the FCC has abdicated its responsibility to ensure that broadband internet access is delivered in a manner consistent with the public interest, this duty has now fallen to the FTC. Access to information is crucial to a functioning democracy, and nowadays broadband internet systems provide a large and growing share of that access. When reviewing the market data provided to you by the NCTA, please note that their reports contain some serious flaws. First, its list of ISP's "competitors" contains few, if any, service providers that could meaningfully reach consumers without using services provided only by ISPs. This makes them dependent on the ISPs themselves, and therefore not really competitors. Second, when presenting statistics about consumer segments that could choose alternatives to an ISP, the NCTA choose to include a non-standard (and misleadingly low) bandwidth threshold of 10Mbps. Anyone who actually uses a low-bandwidth connection like this (e.g. DSL) will tell you that it is no substitute for a true broadband link. With so much important content being delivered as video these days, and with so much compelling information and entertainment existing in other data-intensive forms (e.g. UDTV, interactive massively multiplayer experiences), it is important to get this right. Sensible regulation is not only possible in this market, it is essential. https://arstechnica.com/tech-policy/2018/08/comcastcharter-lobby-asks-ft...