Investors understandably have focused first on whether or not the FCC will upend the broadband Internet sector by deeming broadband a Title II common carrier service for the first time, and second whether or not the FCC actually has the legal/constitutional authority to do so.

  • However, as a result of that political and legal focus, what has been almost completely ignored is the potential multi-billion dollar impact of such an FCC decision, that by definition, would make all currently unregulated and un-metered Internet traffic bits, regulated and metered “telecommunications” tele-bits for the first time.

Simply, deeming broadband Title II legally could compel bit metering and bit payments in the U.S. for the first time.

  • That’s because of the way the law and the forbearance provision are written; they apparently do not allow for any immaculate ruling where the FCC somehow rules the service and carrier of Internet traffic are regulated, but not the Internet traffic itself that is precisely what defines the service and carrier.
  • Legally and logically, one cannot happen without the other.
  • To employ an apt metaphor here, a Title II broadband steamroller is no discriminating surgical scalpel.

Thus, the potential financial liability of deeming broadband Title II could be on the order of tens of billions of dollars a year on major asymmetric Internet traffic originators like Google-YouTube, but also others like Netflix, Amazon, etc. That is because:

  • Broadband (Internet traffic) is currently an unregulated information service.
  • Title II broadband would legally and logically transform unregulated information services traffic into regulated “telecommunications” traffic with cost-based metered pricing by law (See sections 251(b)(5) & 252(d)(2)(A))
  • FCC’s regulatory forbearance authority apparently does not apply to metered “telecommunications.”
  • Many Internet content and apps providers originate much more traffic than they terminate.
  • Unregulated peering is largely free.
  • The operative “telecommunications” metered rate is $.0007 per minute or translated to bits per seconds: 18 cents per gigabit per second or $182 per terabit per second. (See the methodology for all these calculations at the end of this post.)
  • Thus the potential financial liability for every one terabit per second of internet traffic asymmetry would be $5.749b per year, (if the FCC did not devise a new cost-based telecom-Internet blended bit rate.)
  • This means, in particular, Google-YouTube — as the Internet’s largest narrowcaster who sends an estimated 40 times more traffic than they receive — would have a reciprocal compensation cost liability alone of between $5.7b to 16.4b per year, depending on Google’s overall ratio of originating traffic to terminating traffic.

In a nutshell, deeming broadband service to be a regulated telecommunications service by definition simultaneously deems internet traffic to be regulated metered “telecommunications.”

  • Thus the big unintended consequence of deeming broadband Title II is a de facto multi-billion “FCC bit-tax” on asymmetric Internet traffic.
  • The lesson here is perverse legal theories can lead to perverse financial implications.
  • The supreme irony here is that price regulation of Internet traffic (bits) for the first time would force immediate creation of a new inter-carrier compensation regime and universal service subsidy mechanism, that by current law would have to be cost-based. This ironically would force the interests the FCC seeks to protect, Internet content/apps/cloud computing interests, to pay potentially billions of dollars for what they currently get for free.
    • (See below for the detailed explanation of why deeming broadband Title II would have these perverse financial consequences — by law.)

In sum, those advising the FCC that deeming broadband to be a regulated Title II service have not thought through the logical legal and financial implications of that decision.

  • Under the section 10 forbearance language of the statute, the FCC apparently doesn’t have the authority to use a de-regulatory provision to change a statutory definition of “telecommunications” in order to accomplish a re-regulatory purpose.
  • Those advising broadband Title II, risk the FCC profoundly changing the real economics of the Internet, seriously financially disadvantaging the Internet content and application providers they say they intend to protect, and effectively making the current economics of much ecommerce and cloud computing business models unworkable going forward.  

Finally, the last time the FCC imagined that it had the facility and competence to replace the invisible hand of the market with the visible hand of the FCC, it was an unmitigated disaster, creating fiber backbone/CLEC bubbles/crashes, mass CLEC bankruptcies (WorldCom, Global Crossing, PSINet etc.), and the destruction of over trillion dollars in investor and pensioner wealth.

  • (See my 2002 Congressional testimony before the House Financial Services Subcommittee recounting and explaining that financial and business disaster, if you want the gory details.)

*****

Supporting Analysis:

What is the legal and financial analysis behind this conclusion?

Most everyone has overlooked the multi-billion dollar impact of deeming broadband Title II because they were looking only through the net neutrality myopic lens of getting around the D.C Circuit Comcast decision to empower the FCC with police powers over the American Internet.

  • If one steps back and looks for the logical repercussions and legal ramifications of such a ruling, this analysis, and conclusion, becomes more clear.

First, those that know their communications law understand that “telecommunications,” has its own definition separate and distinct from “telecommunications service” and “telecommunications carrier.”

Second, the FCC’s section 10 forbearance authority expressly applies only to a “telecommunications carrier” or a “telecommunications service,” not to “telecommunications” itself. In other words, given the D.C. Circuit Comcast decision, it is doubtful that the FCC has the express authority to forbear from, or effectively ignore, the clear implications of an explicit definition in the law.

  • (As an aside, it is obvious in the way the de-regulatory 1996 Telecom Act forbearance authority was written, that Congress never anticipated the bizarre potentiality where a future FCC would try to reverse engineer the de-regulatory forbearance authority in the Telecom Act to enable and clean up behind FCC re-regulation contrary to Congress’ express intent.)

Third, this is highly problematic for the FCC because of the provisions that govern financial compensation for “telecommunications.”

  • Title II Section 251(b)(5) Interconnection… Reciprocal Compensation,” mandates that the newly Title II broadband provider would have:
    • the duty to establish reciprocal compensation arrangements for the transport and termination of telecommunications.”
  • Title II Section 252(d)(2)(A) “Pricing Standards… Charges for Transport and Termination of Traffic…”
    • For the purposes of compliance by an incumbent local exchange carrier with section 251(b)(5) [above], a state commission shall not consider the terms and conditions for reciprocal compensation to be just and reasonable unless–
      • Such terms and conditions provide for the mutual and reciprocal recovery by each carrier of costs associated with the transport and termination on each carriers network facilities of calls that originate on the network facilities of the other carrier; and
      • such terms and conditions determine such costs on the basis of a reasonable approximation of the additional cost of terminating such calls.”
  • Perversely, these provisions could compel a broadband provider to end unregulated and un-metered Internet peering arrangements and negotiate telecommunications interconnection financial agreements under state public utility commission auspices.
    • This could ensnare all major Internet carriers of Internet traffic like: Level III, Google, Amazon, Skype, Akamai, Limelight, Facebook, and many others.

Fourth, this is highly problematic because it would make resolution of the alreadly mind-bogglingly complex inter-carrier regime for telecommunications (that the FCC hopes to reform and put into better balance over a long ten-year glide-path), dramatically more complex and urgent.

  • (It would also have huge implications for rural carriers who could better build out broadband to all Americans much faster, if they were compensated for terminating Internet traffic.)

Fifth, this is highly problematic in that it could legally compel that U.S backbone carriers, which are among the largest in the world, to start charging or paying foreign companies and foreign countries for any net overage of Internet traffic rather than the current best efforts and generally free Internet peering arrangements.

  • Thus this change in U.S. policy could cascade across the world requiring other countries to meter bits so they did not assume huge new financial liabilities for themselves.
  • In this cash-strapped economic environment, many would jump on any pretext to generate new revenues.
  • The unintended consequence of “opening” the door to bit-metering could be to seriously balkanize the Internet by putting it under the rate-regulation thumb of foreign regulators and the ITU.

Sixth, it is highly problematic because of the enormous potential financial liabilities that classifying broadband as Title II could create.

  • Since Internet traffic has never been classified as a Title II telecommunications, because it was classified as an unregulated enhanced/information service, internet traffic developed massively differently and more asymmetrically than more symmetric “telecommunications” traffic.

What is the methodology for the financial impact on Google for example?

Lets look at the potential implications of this for Google because, as the world-leading video webcaster, Google is estimated to send (narrowcast video) roughly 40 times more bits than it receives in email bits requesting the videos.

  • Thus, moving to Title II could create $5.7-16.4b worth of annual reciprocal compensation payment liabilities going forward for handling Google’s potentially newly defined “telecommunications” traffic.

The math behind the Google liability estimate of $5.7-16.4b per year:

  • Start with the current operative FCC inter-carrier compensation rate of $.0007 per minute for this kind of traffic.
  • Then convert that $.0007 per minute cost into bits per second cost.
    • Assuming a VoIP call is ~64 kilobits per second, the $.0007 per minute is the functional equivalent of $.0001823 per megabits per second, $.18 per gigabit per second, or $182 per terabit per second — for any asymmetric overage of Internet traffic.
  • Then estimate how many terabits a second are on the Internet overall.
    • Using the most recent independent Arbor Networks study, Arbor estimates that the Internet is exchanging ~9 exabytes a month. That would be about ~300 petabytes a day, ~360,000 terabits per hour at peak usage, or ~100 terabits per second.
  • The Arbor Networks study estimates Google’s traffic to be 6% of total Internet traffic, so Google generates about 6 terabits per second world wide.
    • If we estimate that 1/2 of the traffic is U.S. (~1/2 of Google’s revenues are U.S.) that suggests Google uses ~3 terabits per second subject to U.S. FCC jurisdiction.
  • Now lets see how much a terabit per second of net overage traffic would cost someone like Google.
    • Take the FCC intercarrier derived rate of $182 per terabit per second times 3600 seconds in an hour, times 24 hours, times 365 days… and a terabit per second reciprocal overage would cost $5.749b in reciprocal compensation liabilities.
  • Now assuming Google uses the 3 terabits a second above and sends 2-1 more traffic than it receives it would cost Google ~$5.7b a year given current FCC rates.
    • If Google’s reciprocal ration was 5-1 it would cost Google ~$11.5b a year, 10-1 would be $14b, and 40-1 would be $16.4b.

 

Investors understandably have focused first on whether or not the FCC will upend the broadband Internet sector by deeming broadband a Title II common carrier service for the first time, and second whether or not the FCC actually has the legal/constitutional  authority to do so.

  • However, as a result of that political and legal focus, what has been almost completely ignored is the potential multi-billion dollar impact of such an FCC decision, that by definition, would make all currently unregulated and un-metered Internet traffic bits, regulated and metered “telecommunications” tele-bits for the first time.

Simply, deeming broadband Title II legally could compel bit metering and bit payments in the U.S. for the first time.

  • That’s because of the way the law and the forbearance provision are written; they apparently do not allow for any immaculate ruling where the FCC somehow rules the service and carrier of Internet traffic are regulated, but not the Internet traffic itself that is precisely what defines the service and carrier.
  • Legally and logically, one cannot happen without the other.
  • To employ an apt metaphor here, a Title II broadband steamroller is no discriminating surgical scalpel.

Thus, the potential financial liability of deeming broadband Title II could be on the order of tens of billions of dollars a year on major asymmetric Internet traffic originators like Google-YouTube, but also others like Netflix, Amazon, etc. That is because:

  • Broadband (Internet traffic) is currently an unregulated information service.
  • Title II broadband would legally and logically transform unregulated information services traffic into regulated “telecommunications” traffic with cost-based metered pricing by law (See sections 251(b)(5) & 252(d)(2)(A))
  • FCC’s regulatory forbearance authority apparently does not apply to metered “telecommunications.”
  • Many Internet content and apps providers originate much more traffic than they terminate.
  • Unregulated peering is largely free.
  • The operative “telecommunications” metered rate is $.0007 per minute or translated to bits per seconds: 18 cents per gigabit per second or $182 per terabit per second. (See the methodology for all these calculations at the end of this post.)
  • Thus the potential financial liability for every one terabit per second of internet traffic asymmetry would be $5.749b per year, (if the FCC did not devise a new cost-based telecom-Internet blended bit rate.)
  • This means, in particular, Google-YouTube – as the Internet’s largest narrowcaster who sends an estimated 40 times more traffic than they receive — would have a reciprocal compensation cost liability alone of between $5.7b to 16.4b per year, depending on Google’s overall ratio of originating traffic to terminating traffic.

In a nutshell, deeming broadband service to be a regulated telecommunications service by definition simultaneously deems internet traffic to be regulated metered “telecommunications.”

  • Thus the big unintended consequence of deeming broadband Title II is a de facto multi-billion “FCC bit-tax” on asymmetric Internet traffic.
  • The lesson here is perverse legal theories can lead to perverse financial implications.
  • The supreme irony here is that price regulation of Internet traffic (bits) for the first time would force immediate creation of a new inter-carrier compensation regime and universal service subsidy mechanism, that by current law would have to be cost-based. This ironically would force the interests the FCC seeks to protect, Internet content/apps/cloud computing interests, to pay potentially billions of dollars for what they currently get for free.
    • (See below for the detailed explanation of why deeming broadband Title II would have these perverse financial consequences — by law.)

In sum, those advising the FCC that deeming broadband to be a regulated Title II service have not thought through the logical legal and financial implications of that decision.

  • Under the  section 10 forbearance language of the statute, the FCC apparently doesn’t have the authority to use a de-regulatory provision to change a statutory definition of “telecommunications” in order to accomplish a re-regulatory purpose.
  • Those advising broadband Title II, risk the FCC profoundly changing the real economics of the Internet, seriously financially disadvantaging the Internet content and application providers they say they intend to protect, and effectively making the current economics of much ecommerce and cloud computing business models unworkable going forward.

Finally, the last time the FCC imagined that it had the facility and competence to replace the invisible hand of the market with the visible hand of the FCC, it was an unmitigated disaster, creating fiber backbone/CLEC bubbles/crashes, mass CLEC bankruptcies (WorldCom, Global Crossing, PSINet etc.), and the destruction of over trillion dollars in investor and pensioner wealth.

  • (See my 2002 Congressional testimony before the House Financial Services Subcommittee recounting and explaining that financial and business disaster, if you want the gory details.)

*****

Supporting Analysis:

What is the legal and financial analysis behind this conclusion?

Most everyone has overlooked the multi-billion dollar impact of deeming broadband Title II because they were looking only through the net neutrality myopic lens of getting around the D.C Circuit Comcast decision to empower the FCC with police powers over the American Internet.

  • If one steps back and looks for the logical repercussions and legal ramifications of such a ruling, this analysis, and conclusion, becomes more clear.

First, those that know their communications law understand that “telecommunications,” has its own definition separate and distinct from “telecommunications service” and “telecommunications carrier.”

Second, the FCC’s section 10 forbearance authority expressly applies only to a “telecommunications carrier” or a “telecommunications service,” not to “telecommunications” itself. In other words, given the D.C. Circuit Comcast decision, it is doubtful that the FCC has the express authority to forbear from, or effectively ignore, the clear implications of an explicit definition in the law.

  • (As an aside, it is obvious in the way the de-regulatory 1996 Telecom Act forbearance authority was written, that Congress never anticipated the bizarre potentiality where a future FCC would try to reverse engineer the de-regulatory forbearance authority in the Telecom Act to enable and clean up behind FCC re-regulation contrary to Congress’ express intent.)

Third, this is highly problematic for the FCC because of the provisions that govern financial compensation for “telecommunications.”

  • Title II Section 251(b)(5) Interconnection… Reciprocal Compensation,” mandates that the newly Title II broadband provider would have:
    • the duty to establish reciprocal compensation arrangements for the transport and termination of telecommunications.”
  • Title II Section 252(d)(2)(A) “Pricing Standards… Charges for Transport and Termination of Traffic…”
    • For the purposes of compliance by an incumbent local exchange carrier with section 251(b)(5) [above], a state commission shall not consider the terms and conditions for reciprocal compensation to be just and reasonable unless–
      • Such terms and conditions provide for the mutual and reciprocal recovery by each carrier of costs associated with the transport and termination on each carriers network facilities of calls that originate on the network facilities of the other carrier; and
      • such terms and conditions determine such costs on the basis of a reasonable approximation of the additional cost of terminating such calls.”
  • Perversely, these provisions could compel a broadband provider to end unregulated and un-metered Internet peering arrangements and negotiate telecommunications interconnection financial agreements under state public utility commission auspices.
    • This could ensnare all major Internet carriers of Internet traffic like: Level III, Google, Amazon, Skype, Akamai, Limelight, Facebook, and many others.

Fourth, this is highly problematic because it would make resolution of the alreadly mind-bogglingly complex inter-carrier regime for telecommunications (that the FCC hopes to reform and put into better balance over a long ten-year glide-path), dramatically more complex and urgent.

  • (It would also have huge implications for rural carriers who could better build out broadband to all Americans much faster, if they were compensated for terminating Internet traffic.)

Fifth, this is highly problematic in that it could legally compel that U.S backbone carriers, which are among the largest in the world, to start charging or paying foreign companies and foreign countries for any net overage of Internet traffic rather than the current best efforts and generally free Internet peering arrangements.

  • Thus this change in U.S. policy could cascade across the world requiring other countries to meter bits so they did not assume huge new financial liabilities for themselves.
  • In this cash-strapped economic environment, many would jump on any pretext to generate new revenues.
  • The unintended consequence of “opening” the door to bit-metering could be to seriously balkanize the Internet by putting it under the rate-regulation thumb of foreign regulators and the ITU.

Sixth, it is highly problematic because of the enormous potential financial liabilities that classifying broadband as Title II could create.

  • Since Internet traffic has never been classified as a Title II telecommunications, because it was classified as an unregulated enhanced/information service, internet traffic developed massively differently and more asymmetrically than more symmetric “telecommunications” traffic.

What is the methodology for the financial impact on Google for example?

Lets look at the potential implications of this for Google because, as the world-leading video webcaster, Google is estimated to send (narrowcast video) roughly 40 times more bits than it receives in email bits requesting the videos.

  • Thus, moving to Title II could create $5.7-16.4b worth of annual reciprocal compensation payment liabilities going forward for handling Google’s potentially newly defined “telecommunications” traffic.

The math behind the Google liability estimate of $5.7-16.4b per year:

  • Start with the current operative FCC inter-carrier compensation rate of $.0007 per minute for this kind of traffic.
  • Then convert that $.0007 per minute cost into bits per second cost.
    • Assuming a VoIP call is ~64 kilobits per second, the $.0007 per minute is the functional equivalent of $.0001823 per megabits per second, $.18 per gigabit per second, or $182 per terabit per second — for any asymmetric overage of Internet traffic.
  • Then estimate how many terabits a second are on the Internet overall.
    • Using the most recent independent Arbor Networks study, Arbor estimates that the Internet is exchanging ~9 exabytes a month. That would be about ~300 petabytes a day, ~360,000 terabits per hour at peak usage, or ~100 terabits per second.
  • The Arbor Networks study estimates Google’s traffic to be 6% of total Internet traffic, so Google generates about 6 terabits per second world wide.
    • If we estimate that 1/2 of the traffic is U.S. (~1/2 of Google’s revenues are U.S.) that suggests Google uses ~3 terabits per second subject to U.S. FCC jurisdiction.
  • Now lets see how much a terabit per second of net overage traffic would cost someone like Google.
    • Take the FCC intercarrier derived rate of $182 per terabit per second times 3600 seconds in an hour, times 24 hours, times 365 days… and a terabit per second reciprocal overage would cost $5.749b in reciprocal compensation liabilities.
  • Now assuming Google uses the 3 terabits a second above and sends 2-1 more traffic than it receives it would cost Google ~$5.7b a year given current FCC rates.
    •  If Google’s reciprocal ration was 5-1 it would cost Google ~$11.5b a year, 10-1 would be $14b, and 40-1 would be $16.4b.

A common tactic of net neutrality proponents is to assert their desired outcome repeatedly in hopes that it becomes conventional wisdom. Now the Open Internet Coalition asserts that Title II for broadband would be a solid legal foundation” for the FCC, while FreePress asserts broadband Title II would provide the FCC a “sounder legal basis” for its broadband agenda.

  • Fortunately, under the rule-of-law, legal authority simply cannot be asserted or deemed “solid” or “sound” by political acclamation, it ultimately must be proven and affirmed as solid and sound by a full court process (in the absence of Congress passing a new law.)

Surely the FCC understands that the courts ultimately will decide if any legal analysis defending Title II broadband is solid/sound, especially given:

  • The recent D.C. Circuit Comcast decision (which the FCC is not challenging);
  • Broadband has never been classified as Title II; and
  • The FCC is hardly a disinterested observer in trying to determine the boundaries of its own authority.

In the Open Internet reply comments, there are many substantive legal analyses strongly indicating that any FCC decision deeming broadband to be Title II would not be on a solid/sound legal foundation. For just three of the most notable analyses see:

  • Former Clinton Administration Solicitor General Seth P. Waxman’s legal analysis here;
  • Former FCC Associate Bureau Chief Barbara Esbin’s legal analysis here; and
  • Former Carter Administration, Assistant to the Solicitor General, H. Bartow Farr’s III, First Amendment analysis here.

There are also a slew of additional excellent legal analyses in association/company filings that strongly undermine any assertion that the FCC has clear authority to deem broadband to be common carrier regulated for the first time.

The bottom line here is that the FCC would be very hard pressed to claim that any potential legal authority it has to deem broadband to be common carrier regulated rests on a “solid legal foundation,” or “sound legal basis,” until the D.C. Circuit rules on that specific question.

Given that the FCC’s legal authority is, and will remain, an open question until the D.C. Circuit ultimately rules, the FCC should be exceptionally deliberate in this process.

  • In the event that the FCC somehow tentatively concludes it believes it has the authority to deem broadband to be Title II, the FCC should indicate that the FCC would stay, and not implement, any such decision until the D.C. Circuit ultimately rules on the question.

For the FCC to unilaterally deem broadband to be regulated based on questionable legal authority and then try to implement it before the question of legal authority is resolved by the D.C. Circuit, would irresponsibly create a potentially highly destructive double-whipsaw dynamic for both the Nation’s broadband economy/investment and the FCC’s National Broadband Plan.

Simply, the prospect of the FCC reversing longstanding foundational policy… only to be likely re-reversed by the D.C. Circuit months later… would be a predictable and monumental policy disaster — the worst of all worlds for everyone — destructive chaos with nothing to show for it.

  

FOR IMMEDIATE RELEASE  April 27, 2010 Contact: Scott Cleland 703-217-2407

  

Scott Cleland, Chairman NetCompetition.org, Releases Statement Regarding FCC Open Internet Field Hearing in Seattle

 

WASHINGTON – Scott Cleland, Chairman of Netcompetition.org, released the following statement regarding the Federal Communication Commission’s hearing in Seattle focused on the FCC’s Open Internet proposed regulations.

 

  • “I am concerned that the FCC’s latest Open Internet regulation hearing indicates that many special interests are still pushing the FCC hard to implement unnecessary, unwarranted, un-justified, and unauthorized net-neutrality regulations, by deeming broadband to be a regulated common carrier service for the first time.”
  • “Deeming broadband to be a regulated telephone service would be a “lose-lose” dynamic: first a long-shot, bet-the-farm gamble that the FCC would very likely lose in court, and second, a losing approach for getting broadband to all Americans fastest.”
  • “Nothing would put America behind more than slamming the brakes on current robust private broadband investment, and doing a U-turn back in time to impose 19th century, railroad-style regulation on the 21st century Internet.”  

  

NetCompetition.org is a pro-competition e-forum representing broadband interests. See www.netcompetition.org.

###

At the recent Senate Health IT hearing, it was very good to hear Senator Wyden say that it’s “appropriate for Congress… to start thinking… about an HOV lane for e-care for wireless broadband” and questioning why an emergency healthcare service should not be accorded priority transmission over less important/urgent services.

  • This is a much more realistic, reasonable, and nuanced point-of-view than Senator Wyden’s original net neutrality stance a few years ago when he said that: “all bits are created equal” on the Internet.

Senator Wyden’s moderating view on net neutrality reflects a better and growing understanding of how essential reasonable network management is. Communications networks have long accorded priority to first responders in a crisis.

The essential needs for prioritization of Internet traffic and reasonable network management are basically two-fold:

  • First, just like any computer must have a program that schedules or puts different processing tasks in a priority queue in order to function and function with quality and reliability, the Internet at large is like a computer that needs the capability to prioritize and put different traffic in a priority queue so that all parts of the Internet can function with quality and reliability.
    • Urgent-emergency traffic comes before non urgent, real-time voice before non-real time, more quality-sensitive services before less quality-sensitive services, etc.
  • Second, the more people think about the issue of net neutrality the more it becomes obvious that all bits/info are not equal, but that bits have a natural and reasonable hierarchy of priorities to them.
    • For more detail on this natural hierarchy concept please see my thought-provoking post:
      • A Maslow “Hierarchy of Internet Needs?” — Will there be Internet priorities or a priority-less Internet?”  

This post today is notable because it shows that, as people learn more, and better understand the reality of competing priorities and services on the Internet, there is naturally more recognition of the essential need for reasonable network management of the Internet’s very different component networks, in order to make the overall Internet work the way we all expect and need it to work.

  • The Internet does not just magically run itself, it requires purposeful, professional, adaptable, innovative, and reasonable network management.

At core, as Senator Wyden is recognizing, Congress, not the FCC, sets National priorities… and Congress does not mandate there be no priorities…

 
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