
Y Combinator has filed an official comment with the FCC - nRike
http://blog.ycombinator.com/y-combinator-has-filed-an-official-comment-with-the-fcc
======
harrystone
I appreciate what Alexis is trying to do here but I hope he isn't assuming
that the FCC just doesn't understand the problem. That's how this reads to me.
Maybe the idea is to be diplomatic. I don't think the FCC cares. The FCC
understands what is going on and it wants to do whatever is best for the FCC.

The best thing for tech companies to do is to start destroying some political
careers. That's the only thing the machine understands and the only thing it's
really going to respond to.

~~~
alexqgb
That's the essence of contemporary lobbying. Most legislators can be persuaded
with campaign contributions (the carrot) but those that can't get threatened
with the stick, which comes in the form of a previously unheard of but
suddenly flush primary opponent.

Add gerrymandering to the mix, and this tactic becomes even harder to resist,
since the effective sidelining of an opposing party means that no matter what
else happens, the seat in question stays with the side that already holds it.
This is what people mean by "safe" seats, by the way. They're safe for the
_party_. Particular incumbents, not so much.

So yes. If you have a realistic hope of getting what you want it's because
you're known to have the power to end careers. If legislators refuse to
cooperate, their prospects dim. If an agency gets uncooperative, the
legislators who oversee it turn the budget screws, causing pain and wrecking
livelihoods until the backer with the biggest stick wins. These are the
mechanics of regulatory capture, and they're in operation every day.

Obviously, all of this deeply depressing, and provides an excellent argument
for getting private finance out of elections altogether, since that really is
the mechanism upon which American-style corruption depends. And while we're at
it, de-rigging the vote with non-partisan redistricting and establishing a
nation-wide version of the (pre-gutted) Voting Rights Act would go a long way
in fostering a government of, by, and for the people.

But in the meantime, when our systems is less like a democracy and more like
an oligarchy, getting what you want means playing by the rules that exist. And
that means lobbying with both carrot and stick. They hit you, you hit back.
And not only do you hit back harder, you hit back so hard that they will never
get up again. That's what the SOPA/PIPA backlash did: threatened a sweeping
act of maximum violence to an unprecedented number of careers.

It was brutal and it was ugly, but it worked. And it did so when there's not
much else that does.

~~~
EGreg
I'm always curious as to why people think politicians are more motivated by
reelection prospects that, say, their legacy or actually representing their
personal views or convictions. I mean, I can understand why the ones that make
it into office are the ones that fight hard to get elected in the first place,
but once they are there, why wouldn't you expect a lot of them to take pride
in actually representing their districts and really doing a good job in a
representative democracy? I've always wondered why reelection is more
important to these people supposedly then every other incentive! Can someone
elaborate as to why this assumption is always made?

~~~
vidarh
Some do. But consider some simple mechanics of it:

It _you_ care about your legacy, and your _opponent_ only cares about getting
(re-)elected to benefit from the position, your opponent is at an advantage:
Your opponent does not need to "waste" time, money and effort on things that
does not improve their chances at (re-)election.

~~~
EGreg
If doing the job IS wasting time, that means the incentives are all wrong. But
still, who says that re-election is the goal? What about the places where they
are limited to only 2 terms? How could re election explain ther second term
actions? Or are people going to claim that at that point they're all captured
by te industry using the revolving door?

------
pdkl95
> "...so let’s reclassify broadband as the public utility we know it to be."

Thank you _very_ much for writing that! (and the letter in general!)

~~~
Shivetya
are we talking only hard wired (cable/fiber) or wireless as well? I would not
be surprised if costs rise as the provider, similar to who provides natural
gas to my area, gets paid a wonderful fee regardless of how much gas i
actually use. Then there are all these permitted charges for billing, special
taxes, and the like, which raised my gas bill independent of my usage and gas
prices.

We might not get what we want or expect. However do not think that I agree
with services like Netflix paying more for priority when I am already paying
for the bandwidth

------
sundance0
> Y Combinator is Silicon Valley’s premiere early stage investor.

Shouldn't it be 'premier'? I know, not a big deal, but a mistake on the first
line doesn't scream 'Best in the Business' if you ask me.

~~~
alexis
Fixed. Thanks. I can't tell you how many times I and others read over that and
somehow missed it. So it goes with typos.

~~~
jacquesm
Typos tend to materialize when you hit 'submit', 'publish' or other similarly
labeled buttons. Very annoying. At least we've left the days of lead type
behind so fixing is a bit quicker.

~~~
vacri
Sometimes I wonder if those buttons have some kind of 'scramble grammar' logic
built into them...

------
DigitalSea
I said this in a comment a couple of months back on the subject, companies for
net neutrality need to start lobbying. I understand Reddit, Y! Combinator and
pretty much every company with a conscious who cares about the Internet all
have good intentions and have more reasons than most to see fair
laws/legislation based around the Internet. But the sad reality is the FCC is
a mere Government agency and words are not enough.

Look at those who are against net neutrality, those who stand to gain the most
from opposing it: ISP's. I can't recall where I saw it, but it was an
infographic/table showing which companies/organisations have been spending
lobbyist cash on getting their archaic and unfair legislation through via the
FCC. It seems as though spending has increased over the years in the form of
donations and propaganda.

If the likes of Google, Reddit and Y! Combinator want to see a fair Internet,
they need to combine some cash into a pool and use it to lobby the right parts
of the system. Sadly we live in a world where money talks and words are
ignored. I have seen a lot of companies speaking out, but maybe it is time to
consider changing tactics when a public statement from Google on the subject
is basically ignored. Pull out those wallets and start spending guys, it's the
only way.

~~~
chimeracoder
> Y! Combinator

This is the first time I've seen this misconception, and I have to admit it
make me chuckle a bit.

"Y!" is a trademark of Yahoo, which has no connection to Y Combinator (which
is spelled without any exclamation mark).

~~~
DigitalSea
I had just finished drafting up an article on Yahoo when I wrote that, so in
my head I had the letter Y followed by an exclamation mark. Surprised, it's
not a mistake a lot of people frequently make.

------
sillysaurus3
Do such comments have any effect? It's hard to overlook that money seems to
drive American politics moreso than public opinion (with the exception of the
presidential elections).

I think that YC will become increasingly prominent in politics, because the
tech sector has to in order to maintain control of its own fate. It'll be
interesting to see what other moves YC will make.

~~~
tokenadult
Public comments are routine in setting administrative law. (The concept is
called notice-and-comment.) Congress gives the administering agency authority
to make an administrative rule, and that rule can only happen after a public
notice period about the proposed rule, during which any member of the public
can comment on the proposed rule. Rules are often modified during the public
comment period, which will be reflected when the rule is finally published.

Your point is well taken that well organized (not always well moneyed) narrow
interest groups can often get their way in the legislative or administrative
rule-making process simply by being organized and cohesive. That is why
public-choice theory[1] suggests that representative democracy cannot always
achieve disinterested action in favor of the abstract public good. But what we
deal with is a system that is imperfect, but better than other systems of
government that have been tried, in the comparison that Churchill
popularized.[2]

[1]
[http://www.econlib.org/library/Enc/PublicChoice.html](http://www.econlib.org/library/Enc/PublicChoice.html)

[2] [http://richardlangworth.com/worst-form-of-
government](http://richardlangworth.com/worst-form-of-government)

------
zmanian
A lot of folks on the legal/policy side of this debate believe that a
regulator can distinguish between network administration that is monopolistic
rent seeking and that which is value added services.

I'm very suspicious of this as an engineer. I suspect it is very hard to tell
the difference. In a competitive environment, we can more easily discover the
difference. I strongly prefer imposing competition at the last mile rather
than the EFF's suggestion of Title 2 + forebearance...

~~~
sdenton4
Right. We've had 'competition' in the last mile for the last twenty years, and
it's led to terrible service and slower broadband than anywhere else in the
developed world. Because that 'competition' leads to lots of local monopolies
of the worst sort. We've already discovered the difference on this issue.

~~~
snogglethorpe
Isn't the issue really those square quotes? Maybe the U.S. nominally has such
competition, but based on what I've read, it sounds like most people don't
feel they have much actual choice.

Compare this to a place like Tokyo, where there's a vast number of _real_
competitors for both last-mile infrastructure (wires / low-level
communication) and ISP services, and perhaps even more critically, those two
components seem to be largely decoupled. That decoupling seems like it would
go a long way in helping to avoid the sort of net-neutrality shenigans than
seem to be occurring with U.S. ISPs these days, by dramatically decreasing
barriers to entry for new ISPs.

------
TomGullen
One thing that seems to get me is most of this sort of action is defensive,
they propose a new bill and the population has to respond on mass to have it
rejected and put us back to square one.

They then go away, rephrase, and we're on the defensive again. Eventually,
people who only defend will capitulate. You can't win if all you do is defend.

------
natch
"Let me be clear: we need a bright-line, per se rule against discrimination,
access fees, and paid prioritization on both mobile and fixed."

It would be hard to be less clear than this. When you have a comma-separated
list of things you want a rule against, you need to either repeat the word
"against" or risk having people at the FCC, who may just be dumb enough to
make the mistake, think that you mean you want a rule against only the first
thing you mention.

A naive reading of this (again, this is the FCC) would be that you mean we DO
need access fees and paid prioritization, which I guess is the opposite of
what you mean.

~~~
jdoliner
I think it's pretty unlikely that the FCC is going to try to follow this
letter exactly only to make a semantic slipup like the one you describe. I
don't know why you think the people at the FCC are dumb. They do seem to be an
organization with several conflicts of interest, but I think they're capable
of figuring this sentence out.

------
theiostream
The same way capitalist concentration made building a small business very hard
by the start of the 20th Century, the same process is taking place right now
with the Internet. We usually don't notice or even like it (why, isn't it
great to have every service in the same place?), but it is a tendency. Many
arguments in favor of the small business and the virtues of free competition
that were used back then are being used now by this post. The post even
acknowledges that "the world isn't flat", but presumes the Internet needs to
be, as if it was isolated from the rest of the system.

Even if net neutrality were approved, I don't think that unless there are
other technological revolutions that open new sectors up like the PC or the
Internet were, that subdivisions of large companies will be responsible for
most new stuff, taking the most of the market for itself anyway and making
competition harder, as we can see today in many ways. It'd just be a (very
positive) way to preserve the current state of things a while longer, but not
something capable of keeping the Internet "flat" in the long term.

------
andrewescott

      startups would struggle to compete against those who were
      able to afford paying for a fast lane--or an exclusive
      fast lane. Even the slightest discrimination or paid
      prioritization significantly affects startups, as 
      microseconds matter with both webpage-loading and 
      real-time content.
    

This suggests that startups struggle to compete against those who are able to
pay to use CDNs to improve their webpage-loading times. However, this is
clearly not the case, and undermines the argument.

If a "fast lane" cost as much as using a CDN, then presumably most startups
wouldn't have a problem with it.

------
jjmocko
That was well written, and provided a deep understanding of the topic. I
really hope the FCC will listen to such reasoned responses, and not to big
monied interests.

~~~
anigbrowl
YC _is_ a big monied interest, it's just one which happens to dovetail with
the views of most HN readers.

------
kennethfriedman
It's great to see more and more organizations taking a public stand - however
it would be even better to see even a hint that a policy-based solution is
coming.

------
lotsofmangos
Apologies for the cynicism, as I do support this letter, however I do think
that some people will read it as reasons to block net-neutrality as
y-combinator is a shopping-list of companies that annoy entrenched interests.

" _It 's the economy, stupid_" has seemingly been replaced with " _It 's my
economy, stupid_", as the mating call of the political class.

------
joelhaus
Todays FCC commissioners have a unique opportunity; they can choose to shirk
their responsibility to the public and kill the promise of the internet or
they can go down in history as its saviors... the commission that preserved
the internet as an economic engine of growth for generations to come.

~~~
nikanj
Preserved it until next year anyway, when the next version of the "we like
money and power" bill is introduced. The problem with fighting big
corporations is that we only need to lose once, and they have a non-trivial
amount of highly motivated people on payroll just to do the fighting.

~~~
joelhaus
A title II classification would be a huge deal. Not that people could rest on
their laurels, but my sense is that it would be more difficult to undo than
you are letting on.

------
robinhoode
What exactly is meant by this? Is there a source behind it?

> The fate of reddit may have been very different if Comcast had discriminated
> against our little two-person-startup in favor of the NBC.com news portal
> and the sites of other news giants.

~~~
omegaham
Comcast owns NBC. They want to have a large news audience to fit their
business model. Reddit directly competes against that, as a news aggregator
collects information from all sorts of places (including those hostile to
Comcast).

Comcast could say, "Well, you're directly competing with our website, and
you're putting hostile articles about us on the front page. We'll just
throttle your access until your users get frustrated and leave." They're not
the government; they can refuse service to whomever they please.

If the FCC doesn't create rules that enforce net neutrality, this is a
reality. And what's more is that no one can stop them otherwise because many
people have no alternative to Comcast. As the South Park episode goes, "Oh,
you must be really bummed. I guess you could switch services... oh... wait,
you can't. We're the only one."

(nipple rubbing intensifies)

Basically, if you have the resources, you can enforce dominance in the market
with money. One of the cool things about Internet startups right now is that
the barrier to entry is pretty low - anyone with a laptop, an Internet
connection, and some pretty cheap web hosting service can create the next
Facebook. The lack of net neutrality changes that.

------
dbpokorny
Why don't we just shut down the FCC? (Serious question)

[http://transition.fcc.gov/Plan-for-Orderly-Shutdown-
Septembe...](http://transition.fcc.gov/Plan-for-Orderly-Shutdown-
September-2013.pdf)

~~~
schwabacher
To answer your question:

Proponents of net neutrality are asking the FCC for new regulation on the
internet in order to prevent ISPs from prioritizing certain traffic over
others. If we were to shut down the FCC, ISPs would be unrestrained.

In other words - the problem with the FCC is not that it is actively doing bad
things, the problem is that it is not doing the job we would like it to.

------
wierdaaron
I didn't know Alexis was a partner at YC. When did that happen?

~~~
mikeyouse
He's officially been on the payroll since 2010;

[http://techcrunch.com/2010/09/01/reddit-cofounder-alexis-
oha...](http://techcrunch.com/2010/09/01/reddit-cofounder-alexis-ohanian-to-
join-y-combinator/)

But yeah, I don't see his name on the partner list;

[http://www.ycombinator.com/partners/](http://www.ycombinator.com/partners/)

------
sethbannon
The EFF set up a nice site that allows you to easily contact the FCC yourself:
[https://www.dearfcc.org/](https://www.dearfcc.org/)

------
mauz
I've heard Alexis say it many times before but I still don't understand what a
flat World Wide Web means.

Could someone explain?

~~~
marvy
As in "level playing field". Might be a reference to this book:
[http://en.wikipedia.org/wiki/The_World_Is_Flat](http://en.wikipedia.org/wiki/The_World_Is_Flat)

------
chris_wot
Er, did you misspell one of their surnames?!?

------
samrt85
yeah i have read about it on google

------
jsonmez
I know I am in the minority here, but while I prefer net neutrality, I don't
support it.

I'd like to have it, but I'd rather not see it enforced, because I believe
private property rights are more important than anything else.

Should we really be able to force someone to use their property an a way that
serves the public interest?

If so, where do we draw the line?

If ISPs start taking money to throttle bandwidth, alternatives will be
established. Perhaps, widespread public wifi will become more prevalent--I
don't know.

But, what I do know is that forcing companies--even if they are big
corporations to use their property in a way we deem in our best interest is a
slippery slope.

Want to call broadband an public utility? Good, then make it one. But, do it
officially...

~~~
raldi
_> Should we really be able to force someone to use their property an a way
that serves the public interest?_

Yes, that's the price of a government-granted monopoly.

 _> If so, where do we draw the line?_

If you don't have a government-granted monopoly, you don't have to be neutral.
For example, that's how the Internet backbone works.

~~~
steamer25
Instead of trying to get politicians and bureaucrats to thoroughly understand
the technology and hoping that they'll steer these monopolies in a favorable
direction, why don't we demand that said monopolies be dissolved? I.e., if the
terms of the deal are going to be altered, why not declare that there may be
two or even several players? Also, why can't this be resolved at the regional
level? Why does Netflix have to be as uniformly slow as obscure-and-poorly-
optimized-cat-pics.com across the entire country?

~~~
arg01
One of the problems is they're natural monopolies. You only need the one data
link and so it's (arguably) more cost effective to have a single regulated
monopoly on the last mile side. You can create hybrid systems (like the UK)
where other businesses buy capacity wholesale from the monopoly provider and
compete over the same infrastructure.

~~~
steamer25
The same could be said of the grocery stores or car dealerships in my town.
The problem is that as soon as you say it'd be more efficient to have all our
eggs in one basket, the human nature of the carrier kicks in and says, "Hey
I've got it made now. I can take it easy because no one's allowed to compete
with me". Unfortunately, hiring some delegate who's multiple-times removed
from the consumer/voter and is likewise unmotivated to improve the situation
doesn't change that.

Yes doing the trenching and tunneling through various neighborhoods is
disruptive and requires heavy machinery, etc. but that's just to create a hole
in the ground. Once some conduit is laid (as a public good by the
municipality?) it should be relatively easy for new carriers to come in and
pull fiber or what-have-you. You just have to make the channel big enough for
e.g., several cables and then you lease the space to the x highest bidders for
five years at a time where x > 1.

There are probably better ways to finance things and minimize the disruption,
etc. but overall it doesn't seem infeasible to me.

------
lifeisstillgood
What about other forms of "neutrality"?

The BBC is required to maintain "balance" over political issues.

Should Google return the same results to all queries (ie no search bubble
allowed?)

Should Facebook (indeed any advertiser) be required to serve the same advert
no matter what the profile of the incoming request? I mean Billboards are
public broadcasts not private to me, why should online advertising be
different? I know it _is_ but that's not the point.

I support net neutrality as it is commonly defined, but I think there are many
other "neutrality" issues that we gloss over happily. I doubt very much Google
will be happy removing the search bubble, and I would be interested in how
much it affects the quality of results.

~~~
parkovski
I think the problem is with choice. I can get either CenturyLink or Cox where
I live, and if they both decide to throttle certain services, I just have to
live with it.

If I don't like Google, I can use Bing, Yahoo, DuckDuckGo, etc. Same with
Facebook.

Or I can start my own. Starting a search engine or social network is easy.
Getting any market share is hard, since Google and FB are doing a good job,
but they know how easily they could be overtaken if they screw up.

I can't start an ISP because I can't use the existing infrastructure and I
can't afford to build my own. But Google Fiber shows that if I could start one
that doesn't suck, I'd probably have a relatively easy time getting customers,
because the competition is so bad.

I agree though, Google and FB make some choices we probably don't like, but
it's impossible to regulate everything (and most people wouldn't want to), so
we leave it for cases where the free market has proven not to work.

