Here is my response to the FCC’s NPRM 16-106 on privacy.
With this NPRM, the FCC attempts to promote rules to regulate broadband privacy under the ruse of protecting consumers. This response has discussed the highly concentrated online advertising industry and the increasing market share and revenue enjoyed by Google. It further explains that the real reason for the rules is to create barriers to entry to the online marketing industry, specifically to make advertising products and services from broadband providers more difficulty and costly for consumers to use through a convoluted opt-in/opt-out scheme. The effect of such rules will be to retard the competition and innovation that consumers and advertisers demand for alternative ad-serving information platforms and to protect the entrenched interest of the current advertising behemoths.
Broadband providers’ sponsored data products provide users more transparent, secure, and private interactions than the current paradigm of profile based pay per click advertising. Sponsored data products also help reduce the cost of broadband subscriptions, something valued by all subscribers but particularly important to people of low income. In addition small and medium-sized enterprises can take advantage of these products because they do not require technical expertise or a large budget.
The proposed privacy rules create untenable regulatory asymmetry and distortion, put consumers at risk for confusion and misinformation, and deter much needed competition and innovation in ad serving technology. The proposed regulations should not be supported.
Because the FCC is experiencing record delays in rendered the submitted comments to this week’s proceedings, a reported 100,000 comments in the backlog, I enclose a copy of my confirmation to prove that I did submit before the deadline of 11.59.59 on May 27, 2016.
Update May 31, 2016
My response to NRPM 16-106 is now available on the FCC’s website.