CDT Reply Comments in the matter of Broadband Industry Practices
CDT does not believe the Commission should try to adopt rules regulating network management practices. In these reply comments, however, CDT emphasizes that:
- The Commission should take this opportunity to provide some principle-level guidance relating to discrimination, by amending its broadband Policy Statement;
- Network management policies aimed at security threats are different from those aimed at congestion, and the two may warrant separate policy analyses;
- Network providers managing traffic for congestion reasons should seek evenhanded means, such as usage-based pricing; and
- Increased transparency concerning traffic management practices is both feasible and necessary.