WASHINGTON — Net neutrality activists have targeted new Democratic Sen. Kyrsten Sinema of Arizona as a potential obstacle to restoring Title II-based net neutrality rules, though there are a number of other obstacles beyond that.

When Sinema, the first woman elected U.S. senator in that traditionally red state, won the vacated seat of Republican Jeff Flake in November 2018, The New Yorker said it could have been the biggest Democratic victory of the Trump era. But net neutrality activists sure weren’t seeing it that way when it came to the Democrat-backed Save the Internet Act, which has passed the House but needs not only all the Democrats in the Senate but some Republican votes as well.

Last month, Sinema teamed up with Sen. Roger Wicker (R-Miss.), chairman of the Senate Commerce Committee, to form a net neutrality working group focused on “crafting a net neutrality proposal to encourage innovation, boost investment, and close the digital divide.”

Sinema has been working with Republicans on various issues, including joining them to oppose the Green New Deal, voting to confirm Attorney General William Barr when the vast majority of Democrats did not, and most on point for communications watchers, working with Republicans on compromise net neutrality legislation, which is tantamount to heresy in the net neutrality activist playbook.

Activist groups like Demand Progress and numerous Hill Democrats have branded Republican attempts at bipartisan legislation as Trojan Horse efforts to preserve deregulation. So far, those efforts all have excluded common-carrier status under Title II of the Communications Act from the equation, as well as the general conduct standard that expands the Federal Communications Commission’s authority over internet-service conduct beyond bright-line rules.

Demand Progress is suggesting Sinema has jumped on that horse, and was trying to raise money by targeting her for not having signed onto the Save the Internet Act. The group said she is the only holdout among Senate Democrats, which it called totally unacceptable.

“It took more than a year of hard work and grassroots organizing to convince the House of Representatives to pass the Save the Internet Act,” the group said in a fundraising email. “If we’re going to pass the bill in the Senate, we can’t afford to have a Democrat working against us.”

Even with Sinema, prospects for the Democratic-backed ISP reregulation efforts remain slim to none. That’s because more than the two Republicans who broke ranks in the last Congress would need to do so to pass a similar effort, then President Donald Trump would need to sign it. While predicting the president’s actions is a difficult assignment, he is on record supporting the deregulation done under his FCC chairman, Ajit Pai, and has been advised by his administration to veto the attempt to restore the rules.

Unless Democrats and Republicans are able to compromise, the issue is likely to continue to see-saw in the courts, as it has for more than a decade. Currently, a three-judge panel of the U.S. Court of Appeals for the D.C. Circuit is considering a challenge to the Save the Internet Act, which eliminated the 2015 Open Internet rules the Democrats’ bill would restore.

The Congressional Budget Office has concluded that the Save the Internet Act's restoration of the rules against blocking, throttling and paid prioritization would not overly burden ISPs by the measure of the Unfunded Mandates Reform Act.

The act is being debated in the House Tuesday.

CBO 'scored" the bill, which means estimating the costs of implementation, and found that the re-imposition of the rules would be under the $164 million Unfunded Mandates Reform Act threshold in 2019 for lost ISP revenues.

Related: OMB Advises President to Veto Net Neturality Bill

It said that was the conclusion in consultation with ISPs and based on the current use of paid prioritization.

It did not mention the general conduct standard, which is the ISPs chief beef with the reimposition of the rules, that and the Title II authority they argue leaves plenty of room for ex ante regulation, including rate regulation.

CBO estimates that, overall, since the FCC is funded by user fees, the cost of implementing the act would be negligible, increasing oversight and enforcement by the FCC and possible decreasing enforcement by the Federal Trade Commission.

CBO provided a succinct summary of just what the bill does:

"H.R. 1644 would require the Federal Communications Commission (FCC) to return to the regulatory framework for Internet service providers (ISPs) that was in effect as of Jan. 19, 2017. The bill would effectively shift the oversight of ISPs from the Federal Trade Commission (FTC) and the Department of Justice (DOJ) to the FCC by re-designating mobile and fixed-broadband Internet access services as telecommunications services subject to common-carrier laws under title II of the Communications Act of 1934. Thus, the FCC could take enforcement action regarding any unjust, unreasonable, or discriminatory ISP practices.

"H.R. 1644 would repeal the Restoring Internet Freedom Order (FCC 17-166) adopted by the FCC on Dec. 14, 2017, and prohibit its re-issuance in substantially the same form. The bill would restore the Open Internet Order (FCC 15-24) adopted by the FCC on Feb. 26, 2015, and any subsequent regulations in effect on Jan. 19, 2017."