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Survey: Most Verifiable FCC Comments Favor Title II Repeal

Broadband for America is telling the FCC that a study it commissioned found that 69.9% (8,595,090) of the comments in the FCC network neutrality docket that were not either fake or unverifiable international comments favored repealing Title II classification, while only 29.5% (3,622,188) were against repeal.

The study was conducted by data analytics company Emprata. CEO Paul Salasznyk told B&C that the study was "conducted in an independent fashion, forming our own conclusions using the publicly available data."

The study found that of the 21.766 million comments assessed, more than 20.684 million "appear to be artificial, international filings, form letters, and duplicative submissions."

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Broadband for America members include AT&T, CenturyLink, Charter, CTIA – The Wireless Association, Comcast, NCTA – The Internet & Television Association, Telecommunications Industry Association (TIA), and USTelecom Association, representing ISPs opposed to Title II.

Emprata said that, on face value the majority of comments opposed Title II repeal, and that with the duplicative and unverifiable comments removed, that is reversed, but that it was hard to draw any conclusions from the comments one way or the other. "The lack of user authentication by the Electronic Comments Filing System (ECFS) makes it difficult to determine 'genuine' comment submissions," it said. 

"Emprata was also not able to authenticate the filer, address, email, or comment data used for this analysis, nor the methods used to collect those data elements. As a result, it is very difficult to draw any definitive conclusions from the comments found in the docket. Any conclusions that one might draw from the data would be based on the subset of data that they considered to be 'real'."

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For example, net neutrality activists could look at the "unique comments"—as opposed to form letter comments—which were significantly against repealing Title II (1.77 million  against repeal versus only 24 thousand for repeal). "Although these comments represent less than 10% of the total, this is a notable difference," said Emprata.

The study found that over 7.75 million comments (36% of the total) came from fictitious email domains from The study also found that there were 1.72 million unverifiable comments from international addresses in Russia, India, France, and 26 other countries. It said almost all (99.4%) opposed repeal of Title II.

"When accounting for obviously fake email domains (7.75 million) and unverifiable international comments (1.72 million), the overall sentiment of comments is 69.9% in favor of repealing Title II and 29.5% against repealing Title II," said Broadband for America of the study. "The results of the report shed light on the questionable, fictitious sources of many of the comments, specifically the 7.75 million comments that were submitted using a known fake email generator. The findings further underscore the need for Congressional action to address outdated utility regulations and ensure advances in internet technologies are not hindered. We stand ready to work with lawmakers on both sides of the aisle to ensure durable net neutrality principles are enshrined into law."

The study was submitted as comment to the FCC Wednesday, Aug. 30,, the deadline for weighing in on the proposal by FCC Chairman Ajit Pai to roll back Title II and reconsider the rules against blocking, throttling and paid prioritization adopted in the 2015 Open Internet order that reclassified ISPs under Title II common carrier rules, which mandate nondiscriminatory access.

Emprata looked at the 21.766 million comments posted in the Restoring Internet Freedom docket as of Aug. 22, 2017, the original deadline for comment. At press time Aug. 29, the total posted was 21.865 million.

"Today, the telecom industry is touting a study funded by cable lobby group Broadband for America regarding the millions of comments submitted to the FCC’s public docket surrounding the agency’s plan to gut Title II net neutrality rules that prevent companies like AT&T and Verizon from charging extra fees, throttling apps and services, and censoring online content," said Title II fan Fight for the Future. "The most telling statistic in the report is that the unique comments in the docket -- the ones that people took the extra time to write themselves -- are overwhelmingly in favor of Title II net neutrality protections, by more than 73 to 1. So the telecom industry’s own study essentially shows what nearly all other polling on this issue has shown: that they are getting trounced when it comes to public opinion, and people from across the political spectrum overwhelmingly agree that they don’t want their ISPs to have control over what they can see and do on the Internet."

John Eggerton
John Eggerton

Contributing editor John Eggerton has been an editor and/or writer on media regulation, legislation and policy for over four decades, including covering the FCC, FTC, Congress, the major media trade associations, and the federal courts. In addition to Multichannel News and Broadcasting + Cable, his work has appeared in Radio World, TV Technology, TV Fax, This Week in Consumer Electronics, Variety and the Encyclopedia Britannica.