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FCC Ex Parte regarding the Framework for Broadband Internet Service ("the Third Way")

Submission Date: 
09/15/2010

Via ECFS

Marlene Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Room TW-A325
Washington, DC 20554

Re: American Cable Association (“ACA”) Notice of Ex Parte Presentation: Notice of Ex Parte: Framework for Broadband Internet Service, Notice of Inquiry, GN Docket No.10-127.

Dear Ms. Dortch:

On September 14, 2010, Ross Lieberman, ACA, and the undersigned, representing ACA,met with FCC General Counsel Austin Schlick, Deputy General Counsel Julie Veach, and Chris Killion and Royce Sherlock of the General Counsel’s Office, to discuss ACA’s Comments and Reply Comments in GN Docket No. 10-127.

In the meeting, we discussed how departing from the Commission’s highly successful “light touch” regulatory environment for broadband Internet services to impose economic regulation on providers of broadband Internet services risks foisting on smaller providers increased regulatory burdens and costs that will impair their ability to expand their broadband offerings. In particular, we discussed the practical implications of adoption of the “Third Way” proposal put forth in the Notice of Inquiry (NOI) on smaller operators. We also discussed the legal and procedural infirmities of the Commission’s apparent intention to bypass the rulemaking and regulatory flexibility analyses of the Administrative Procedure Act and the Regulatory Flexibility Act and move instead directly from the NOI to a declaratory ruling reclassifying broadband Internet service as a telecommunications service,subject only to those provisions of Title II of the Communications Act over which the Commission declines to exercise its forbearance authority.

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