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Comments on specialized services and wireless in the net-neutrality debate

Recently, the FCC asked for feedback on two issues: how so-called “specialized services” should be exempted from neutrality protections, if at all, and whether open Internet rules should be applied to wireless services in addition to wireline broadband services.

So today, Policy Integrity submitted reply comments in response to these two questions.

In terms of the first issue, we look at economic arguments for why broadband service should be given a broad definition, whereas any exemption for a category of “specialized services” should be very narrowly drawn. Otherwise, the specialized service exemption will become a big loophole for applications and services that basically replace content that travels over the neutral network.

As to the wireless issue, if network neutrality rules are applied to broadband, but not to wireless, ISPs will have incentives to concentrate more of their investment in wireless infrastructure. By contrast, content developers will have incentives to focus more of their efforts on broadband, since their returns will be higher on the open platform. This mismatch of investment incentives could lower the value of both networks for ISPs, content creators, and end-users.

This is part of our on-going work on net-neutrality including a set of original comments on the proposed regulation.