AALL Files Comments in Net Neutrality Proceeding

By Elizabeth Holland

The American Association of Law Libraries (AALL), the Association of Academic Health Sciences Libraries (AAHSL), the Medical Library Association (MLA), and the Special Libraries Association (SLA) filed comments together in the Federal Communication Commission (FCC)’s Open Internet proceeding. The comments, available here, were authored by AALL’s Government Relations Office and Government Relations Committee, with input and examples from AAHSL, MLA, and SLA.

AALL, AAHSL, MLA, and SLA urge the FCC to create open Internet rules that preserve and defend the key principle of network neutrality. Our comments focus on the important role libraries play in providing unbiased access to information over the Internet and, increasingly, as the creators and hosts of information. Libraries, for example, may provide educational opportunities online in the form of Massive Open Online Course (MOOCs) or host information produced by other sources, like state governments and the courts.

Our organizations oppose any open Internet rules that would allow for a tiered system of access, as is presently proposed in the Notice of Proposed Rulemaking’s “commercially unreasonable” standard, which would permit the sanctioning of paid prioritization under Section 706 of the Telecommunications Act of 1996. Paid prioritization inherently favors content providers that can pay fees for favorable treatment, while non-profit content providers like libraries, educational institutions, government agencies, and non-profit organizations are relegated to second-class delivery. We urge the FCC to establish a firm foundation for its open Internet rules by reclassifying broadband Internet access as a telecommunications service under Title II of the Communications Act of 1934, while forbearing from applying any possibly unnecessary, costly, and burdensome regulations. Such reclassification would subject Internet Service Providers (ISPs) to common carrier rules that better ensure equal, nondiscriminatory access to content on the Internet and require ISPs to operate more transparently.

Net neutrality is critical to libraries, their missions, and their patrons.  AALL, AAHSL, MLA, and SLA urge the FCC to create open Internet rules that preserve and defend this key principle. Over 1 million comments on net neutrality were filed with the FCC, which extended the deadline by several days after a crush of traffic to their electronic comment filing system. Though the initial comment period is now closed, a second period for reply comments will run until September 10.

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