As
the FCC has done for all proceedings since Chairman Ajit Pai took over in
January 2017, the FCC released the Fact Sheet and Draft
Order
in the Restoring Internet Freedom
proceeding three weeks in advance of its December 14 vote. In response to the
release, Commissioner Mignon Clyburn published her own Fact Sheet and
Glossary
about the harms she believes the Order will create.
Here
is her definition for “cost-benefit analysis:”
Cost-benefit analysis – Despite insufficient data and
data to the contrary, the Chairman's Order draws conclusions by only accepting
self-serving statements made by large broadband providers. It makes no effort
to verify these claims against the statements these very same companies have
made in filings before the Securities and Exchange Commission (SEC).
However, in the Draft
Order, the FCC concluded that broadband investment declined by 5.6% since the
adoption of the Title II Order. This figure,
compiled by Hal
Singer,
uses data that comes directly from broadband ISP’s 10-Q and 10-K forms, which
are required by the SEC. Even my blog estimating a $5.6 billion
decline
in broadband investment since the Title
II Order, which also was cited in the Draft Order, uses data collected
directly from these filings required by the SEC. Broadband ISPs are reporting
figures to the SEC that are consistent with what they also are telling the FCC;
broadband investment has declined since the Title
II Order was adopted.
For a more accurate
assessment of the FCC’s proposal to conduct a cost-benefit analysis, see this July 2017 Perspectives from FSF Scholars by FSF Senior
Fellow Ted Bolema.
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