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These reply comments were covered by .

Yesterday, OTI filed reply urging the Federal Communications Commission (FCC) to reclassify broadband internet access as a Title II service and to set conduct standards that prohibit ISPs from engaging in discriminatory behavior, improve broadband service transparency and disclosure to better inform consumers, and empower states to build on FCC protections to further protect broadband consumers. These reply comments build on OTI’s previously filed comments in this proceeding.

The FCC’s Notice of Proposed Rulemaking, “In the Matter of Safeguarding and Securing the Open Internet,” proposes to re-establish the FCC’s authority over broadband internet access service (“BIAS”) by classifying it as a telecommunications service and to reinstate rules established in the 2015 Open Internet Order.

OTI supports this endeavor and urges the FCC in its reply comments, specifically, to (1) reinstate conduct standards and rules to prevent any ISP discriminatory practices such as blocking, throttling, and engaging in paid or affiliated prioritization in order to protect BIAS services used to facilitate public safety services and communications; (2) only preempt state and local laws that provide less protection for consumers than rules established by the FCC; (3) restore greater transparency and disclosure requirements and enhance broadband labels by requiring the inclusion of information regarding real-world cost and relevant performance; (4) clearly define zero-rating practices that should be presumptively prohibited such as zero-rating in exchange for commercial advantages and zero-rating some content, applications, and services but not the entire category; and (5) narrow and clarify the definition of “non-BIAS data services” that are exempt from open internet regulation.