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In Reply Comments to FCC, TIA Encourages Flexible Internet Regulation; Says Title II Reclassification Would be Impractical & Harmful

Arlington, Va. (September 15, 2014) – The Telecommunications Industry Association (TIA), the leading association representing the manufacturers and suppliers of high-tech communications networks, today filed reply comments with the FCC on the protection and promotion of the open internet. In the comments, TIA provides extensive support about the "assorted and substantial harms that Title II would cause for the broadband marketplace."

"The United States should continue the light-touch regulatory approach that has fostered innovation, broadband deployment, and investment," said TIA President Grant Seiffert. "American consumers, rather than the government, should decide what combination of price, speed, and capability is best for each individual user. Title II reclassification of broadband Internet access would be impractical, susceptible to court challenges, and prohibitive to much-needed broadband investment."

Below are key points from TIA's comments.

The Record of Comments Filed with FCC Contains a Broad-Based Consensus Against Title II

TIA said, "The opening comments reflect a broad-based consensus that the Commission should adopt any open Internet rules only pursuant to the "blueprint" set forth by the D.C. Circuit, rather than invite the host of problems that would follow were the Commission to reclassify broadband Internet access service under Title II. As discussed further below, commenters from all sectors of the industry warn that reclassification would be unwise as a policy matter and unsound as a legal one. The Commission should firmly reject the heavy-handed Title II approach and extinguish the tremendous uncertainty produced by the revival of this option."

Prioritization Can Be Beneficial If Handled as a Form of Traffic Management

"TIA also agrees with other commenters that prioritization can be beneficial for customers, and to the extent it is separate from specialized services, is a form of traffic management. As some have observed, 'Prioritizing E-911 calls or telemedicine applications ahead of 'cat videos' clearly serves the public interest.' Recognizing that not all uses of our communications infrastructure are equal, the Commission mandates prioritization in the public safety context already. In areas outside of public safety, the Commission should not foreclose particular business models, but continue to encourage experimentation and market responses for market demand."

Driving Continued Investment Enhances Internet Access

"As this updated declaration from the current President of Bell Labs describes, in the four years since the Commission last inquired about specialized services, a common, industrywide understanding regarding the precise scope of this category has not yet developed – a function of the rapid pace of change and innovation that continues to redefine service preferences and needs of end users," as well as lingering regulatory uncertainty. "At the same time, ongoing investment in these types of services – that is, services that typically involve the provision of quality of service or bandwidth guarantees to address sensitivity to either packet loss or packet delay – continues to drive overall network investment, which in turn enhances the capacity for 'best efforts' Internet access services, rather than undermining them."

Read TIA's reply comments sent to the FCC in their entirety at this link.

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About TIA

The Telecommunications Industry Association (TIA) represents manufacturers and suppliers of global communications networks through standards development, policy and advocacy, business opportunities, market intelligence, and events and networking. TIA enhances the business environment for broadband, mobile wireless, information technology, networks, cable, satellite and unified communications. Members' products and services empower communications in every industry and market, including healthcare, education, security, public safety, transportation, government, the military, the environment, and entertainment. Visit for more details.

TIA is accredited by the American National Standards Institute (ANSI), and is a proud sponsor of ANSI’s Standards Boost Business campaign. Visit  for details.