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Municipal Networks and Small ISP Partners to FCC: Title II Not a Problem

A group of municipal leaders and their private sector small ISP partners submitted an ex parte filing with the FCC today stating that they see no reason to fear Title II reclassification of Internet access. The statement, signed by a variety of towns and providers from different areas of the country is reproduced in full:

Dear Chairman Wheeler,

As a group of local governments and small ISPs that have been working to expand the highest quality Internet access to our communities, we commend you for your efforts to improve Internet access across the country. We are committed to a free and open Internet without blocking, throttling, or discriminating by ISPs.

As local governments and small ISPs, we wanted to ensure you are aware that not all local governments and ISPs think alike on matters like reclassification. For instance, on July 18, 2014, the mayors of New York City; Portland, Oregon; and San Francisco called on you to issue the strongest possible rules to guarantee Net Neutrality. Each of these communities is also taking steps to expand and improve high quality Internet access to their businesses and residents.

Our approaches vary but are already resulting in the highest level of service available because we are committed to expanding high quality Internet access to supercharge local economies and improve quality of life. We have no interest in simply replicating older triple play model approaches. We want to build the infrastructure of the future and we see nothing in the proposed Title II reclassification of Internet access that would hinder our ability to do that. As Sonic CEO Dane Jasper has strongly argued, ISPs that don’t want to interfere with their subscribers’ traffic should expect a light regulatory touch.

We thank you for your leadership during this difficult period of transition. We understand that many of our colleagues have trouble trusting the FCC given a history that has, in many cases, ignored the challenges small entities face in this industry. But whether it has been increasing the speed definition of broadband, or calling for the removal of barriers to community networks, we have been impressed with your willingness to take on powerful interest groups to ensure the Internet remains a vibrant, open platform.

We look forward to working with you to ensure that future rules recognize the unique challenges of small providers and innovative approaches to expanding access.

Sincerely,

  • Peter d'Errico, Town of Leverett MA, Municipal Light Plant, Town of Leverett MA Select Board
  • Fletcher Kittredge, President and CEO, GWI, Maine
  • Rick Bates, Town Manager, Town of Rockport, Maine
  • Kevin Utz, Mayor, Westminster, Maryland
  • Dr Robert Wack, Council Member, Westminster, Maryland 
  • R. Brough Turner, Founder and CTO, netBlazr Inc., Boston, MA
  • Pete Ashdown, Founder and CEO of XMission, Salt Lake City, Utah
  • Elliot Noss, CEO, Tucows / Ting
  • Kim Kleppe, Information Systems Director, City of Mount Vernon, Washington
  • Dana Kirkham, Mayor, City of Ammon, ID
  • Levi C. Maaia, President, Full Channel Labs, Warren, Rhode Island

You can also view the PDF of the filing at the FCC website.

For more on Title II and how it may or may not affect municipal networks and their private partners, listen to Chris interview Chris Lewis from Public Knowledge in Episode #138 of the Community Broadband Bits podcast.

Answering Questions About Title II and Munis - Community Broadband Bits Episode 138

As we near the FCC open meeting at the end of next week, when it will decide on both the Chattanooga and Wilson petitions regarding their wish to expand as well as a proposal to reclassify Internet access a Title II service in order to ensure it can maintain the same open Internet we have long loved. We have mostly focused on the muni petitions, but after hearing some concerns from some munis regarding Title II, we realized we have to delve into the Title II reclassification more deeply.

Enter Chris Lewis, VP of Government of Affairs for Public Knowledge. I've always enjoyed talking with Chris on various issues around telecom policy and we asked him to come on and answer some of the questions we have heard.

We talk about the prospects of rate regulation, unbundling, transparency requirements, and the process for filing complaints until Title II. Overall, our conclusion is that the rules as we understand them, are quite reasonable and should not pose a problem to munis that are already committed to providing a high quality service.

You can read a Fact Sheet about the proposed rules here.

Read the transcript from this episode here.

We want your feedback and suggestions for the show - please e-mail us or leave a comment below.

This show is 22 minutes long and can be played below on this page or via iTunes or via the tool of your choice using this feed.

Listen to previous episodes here. You can can download this Mp3 file directly from here.

Find more episodes in our podcast index.

Thanks to Persson for the music, licensed using Creative Commons. The song is "Blues walk."

38 Next Century Cities Leaders Sign Letter to FCC Supporting Local Authority

President Obama suggested restoring local telecommunications authority while visiting Cedar Falls in January and a number of local elected officials were ready to back him up. Leaders from 38 members of Next Century Cities recently submitted a public letter to the FCC urging commissioners to consider local autonomy as they consider the Chattanooga and Wilson, North Carolina, petitions.

Last summer, both communities filed with the FCC seeking relief from restrictive state laws that prevent their broadband utilities from serving surrounding communities. FCC Chairman Wheeler has spoken in support of local authority more than once. Next Century Cities, a coalition of communities that was formed specifically to advance better connectivity, writes:

We write only to urge that, as you consider these petitions, you take proper account of the importance of local choice and autonomy. The benefits of high-quality broadband are now beyond dispute: these projects have stimulated local innovation and economic development, enhanced education, improved government services, and opened new worlds of opportunity to communities and citizens. It is our hope that federal policy will support the realization of these outcomes in our communities and in towns and cities across the country, by empowering every community to meet the needs of their residents.

You can read the full letter [PDF] online to see if your elected officials signed on.

The FCC's decision on the petitions is expected in February.

Comcast Ghostwrites Letters From Elected Officials to FCC

It is common knowledge that Comcast and a number of political leaders enjoy special relationships. Nevertheless, it was still a bit shocking to see the level at which Comcast's army has infiltrated the political process as uncovered in a recent Verge article.

Comcast, Time Warner Cable, AT&T, and CenturyLink lawyers and lobbyists often write legislation for lawmakers to introduce. This past summer, the puppetry went one step further when Comcast crafted letters supporting the Comcast/Time Warner Cable merger. Those letters were then submitted to the FCC from the offices of a number of politicians known to receive support from the cable giant. We applaud both Comcast and their pet lawmakers for their efficiency!

The Verge was also able to obtain email threads that document how lobbyists drafted letters of support and sent them on to local elected officials, who then made insignificant changes in the signature line or transferred the exact language on to official stationery before sending it on to the FCC.

We have taken the liberty of presenting some of the letters below. You can see a few email exchanges that detail the conversation between Comcast lobbyists and political staff.

The Verge spoke with Michal Copps, former FCC Chairman, who now advises at Common Cause:

"When a mayor of a town or a town councilman or a legislator writes in — we look at that, and if someone is of a mind already to approve something like this they might say: ‘ah-ha, see!’" says Copps, who is now an advisor at Common Cause and opposes the merger. "These letters can be consequential, there’s no question about that."

The comment process has been tainted because Comcast has also used gentle nudging to obtain support from organizations benefitting from its charitable foundation. Columbia Professor Tim Wu has studied the potential merger:

"I think they have failed to meet their burden of persuasion that this will make life better for the average American consumer…What does the average American consumer care about? They care about prices being too high. Comcast could have said this merger will lower prices and committed itself to lower prices but it has made no sign that it will do this." 

Wu, who reviewed the documents obtained by The Verge, said that the new information "confirms the impression that evidence that the merger is in the ‘public interest’ is simply being manufactured."

"It’s sort of become an amusement park where the fake stuff outnumbers the real stuff," Wu says. "The fact is a lot of telecom issues are pretty obscure, they often don’t get the public very excited. So what do you do? You buy it."

Apparently, these elected officials did not expect their constituents to notice that they supported one of the most unpopular proposed mergers in history. In order to set the record straight, we encourage constituents to contact them and let them know that you do not support the merger, as they claim you do.

We also suggest that you let them know that you do not cotton to the idea that they let lobbyists put words in their mouths, regardless of the issue.

Most importantly, remember this incident the next time you enter the voting booth.

Supporters Rally Behind Wheeler, Chattanooga, and Wilson: "I Recommend Approval"

FCC Chairman Tom Wheeler released a statement yesterday supporting the concept of local authority for community broadband infrastructure. Chattanooga and Wilson filed petitions to scale back state restrictions last summer. In his statement, Wheeler officially recommended the Commission approve the petitions. If approved, the petitions have the potential to liberate local communities from state restrictions. 

Along with a number of other organizations that advocate local authority, the Institute for Local Self-Reliance supports Chairman Wheeler who said:

Communities across the nation know that access to robust broadband is key to their economic future – and the future of their citizens. Many communities have found that existing private-sector broadband deployment or investment fails to meet their needs. They should be able to make their own decisions about building the networks they need to thrive. After looking carefully at petitions by two community broadband providers asking the FCC to pre-empt provisions of state laws preventing expansion of their very successful networks, I recommend approval by the Commission so that these two forward-thinking cities can serve the many citizens clamoring for a better broadband future.

Chris Mitchell, Director of the Community Broadband Networks Initiative at ILSR.org and the editor of MuniNetworks.org said:

The Chairman's statement is a breath of fresh air. This approach will allow communities with little or no choice in providers to take control of their own connectivity. When local communities have the authority to invest in publicly owned infrastrucuture without state barriers, more businesses and residents have fast, affordable, reliable Internet access. Even just the possibility of a community network can incent large scale providers to improve their services. We are pleased to see Chairman Wheeler both talk the talk and walk the walk of restoring local decision-making authority.

A statement of support quickly followed from the Georgia Municipal Association:

Prohibiting government from providing this economic development infrastructure, or limiting its ability to do so, is counter to the wishes of the community and to the best interest of cities, states and our nation. 

Next Century Cities, the coalition of over 50 communities working to restore local Internet choice, recently delivered a letter [PDF] from 38 member cities to the FCC, urging the Commission to consider local autonomy. Deb Socia, the Executive Director, applauded the statement:

If we want truly next-generation broadband, then cities across the country need to be in the driver’s seat. That’s why they are looking to the FCC to uphold their ability to make the best choices for their communities and residents.

Public Knowledge wrote:

Every community should have the right to determine its broadband needs and the path of its digital future, including the ability to pick competition over monopoly for broadband services. Chairman Wheeler has taken an important first step by advancing these two petitions forward.

The Media Mobilizing Project, involved in efforts to improve connectivity in Philadelphia, stated that it strongly supports Chairman Wheeler's plan to restore local authority:

Philly, every city in PA, and every community nationwide deserves the right to explore high quality competition to our communications monopolies - to drive prices down, quality up, and access to everyone, poor and working people and beyond.  We look forward to Chairman Wheeler's continued leadership on this issue, and expanding options for our communities - who strongly believe that access to high quality communications is a human right.

From Common Cause:

"What a great step approval would be toward bringing broadband to every American,” agreed former FCC Commissioner Michael Copps, now serving as special adviser to Common Cause’s Media and Democracy Reform Initiative. “We built this country with federal and community partnerships for vital infrastructure, and what's more vital than broadband for the 21st century?  A big high-five to Chairman Tom Wheeler and the colleagues who have joined him to push this move.”

The Coalition for Local Internet Choice (CLIC) also passed a "big high-five" to the Chairman:

CLIC applauds Chairman Wheeler for his leadership and recognition that local communities play an integral role in ensuring broadband competition for their residents. This is a big step forward and just the beginning — we look forward to working with the Chairman, the rest of the Commission and other stakeholders to remove barriers to better broadband around the country.

For more on the Chattanooga and Wilson petitions, we encourage you to listen to episode #120 of the Community Broadband Bits podcast, in which we debunk a series of arguments against restoring local authority. 

Chris also had an informative interview with Harold Feld on section 706 in episode #84. In that interview, published well before the Chattanooga and Wilson petitions were filed, the Senior Vice President of Public Knowledge dissected how the DC Circuit Court came to the conclusion that paved the way for the petitions.

Good stuff!

Boston Globe the Latest to Support Local Authority

Yet another major news outlet has endorsed the President's position in support of local telecommunications authority. On January 26th, the Boston Globe went on record to endorse the concept, urging the FCC and Congress to work together to ensure local communities have the right to make their own connecitvity decisions.

The Globe suggested that, rather than allowing the FCC to take the lead with the Wilson and Chattanooga petition decisions, federal lawmakers take action:

A better approach would be for Congress to settle the issue itself, by preventing states from interfering with cities and towns that want to start their own Internet services.

The Globe Editors note that rural areas are the hardest hit by large corporate provider indifference, that it is those same parties that drive the state barrier bills, and that, "This status quo is bad for customers everywhere."

Globe Editors get behind a bill recently introduced by Cory Booker, Claire McCaskill, and Ed Markey that wipes out state barriers in the 19 states where they exist and prevents state lawmakers from enacting new ones. The Globe acknowledges that the support is lopsided today...:

But this shouldn’t be a partisan issue, and it isn’t one on the local level. Red states like Georgia, Kentucky, Iowa, Oklahoma, and Utah all have successful municipal Internet programs. Politicians tempted by campaign contributions from the telecommunications lobby, or skeptical of any proposal backed by President Obama, should remember that consumer protection is an issue that voters of all stripes support.

National Press Follows President Obama to Cedar Falls, Iowa

On January 14th, President Obama visited Cedar Falls, Iowa, to share his strategy to expand high-speed connectivity to more Americans, encourage competition, and galvanize economic development. Obama's plan centers around community networks and he announced that the next step will be eliminating barriers in 19 states that usurp local authority to invest in publicly owned infrastructure.

From his remarks [C-SPAN Video below]:

Today, I'm making my administration's position clear on community broadband. I'm saying I'm on the side of competition. And I'm on the side of small business owners... I'm on the side of students and schools. I believe that a community has the right to make its own choice and to provide its own broadband if it wants to. Nobody is going to force you to do it, but if you want to do it, if the community decides this is something that we want to do to give ourselves a competitive edge and to help our young people and our businesses, they should be able to do it.

The Obama Administration, through the Department of Commerce, recently sent a letter [PDF] to Chairman Wheeler to request the FCC use its authority to end state barriers that block local public investment. The Hill noted the letter and the President's speech together put gentle pressure on the FCC to take steps to restore local authority. The Hill also gave space to the cable industry, naturally opposed to restoring local authority after millions of lobbying dollars invested in passing anti-competitive legislation.

InfoWorld also pointed out cable industry opposition to the Obama proposal, noting that they were ready to mount a strong offense and will likely join Congressional Republicans to fight any roll-back of state barriers. A decision from the FCC on whether or not to change state laws in North Carolina and Tennessee is expected in February.

As for the incumbents, there was no love lost between the President and the big players, as Multichannel News reported:

He said in many places big companies are "doing everything they can to keep out new competitors."

…they were at the whim of whatever Internet service provider happened to be around, and and when they had problems they got stuck on hold watching a spinning icon, waiting and waiting and waiting and wondering why rates keep getting "jacked up." Ouch. 

Other national outlets that covered the speech included the New York Times, the Washington Post, Ars Technica, Fierce Telecom, and NexGov. We came across so many stories we stopped counting.

Local coverage included stories from the Sioux City Journal, the Quad City Times, the Gazette, and the Waterloo Cedar Falls Courier. Mayor Jon Crews told the Courier:

“This is good for attracting companies that have higher wages for technical positions,” Crews said. “Obviously to be recognized by Google and the president of the United States in two months time is pretty awesome.”

As the President noted in his speech, Google named Cedar Falls the best city in Iowa for e-commerce due to its municipal fiber optic network.

Marc Reifenrath, local business owner of a web design, development and digital strategy agency called Spinutech introduced the President:

In our early years it would have been easy to move our headquarters to another city, really anywhere. Thanks in part to its high speed internet, Cedar Falls has always made it easy for us to grow our business. Today, Spinutech has clients in all 50 states and eight countries. In talking with these clients, time and again it is proven just how fortunate we are.

Whether or not local authority is restored in the 19 states in question, it is important that local communities remember the role of vision, which the President pointed out in his speech:

Now, in Cedar Falls, things are different. About 20 years ago, in a visionary move ahead of its time, this city voted to add another option to the market and invest in a community broadband network. Really smart thing you guys did. It was a really smart thing you guys did. And you've managed it right here at Cedar Falls Utilities. And then a few years ago, you realized that customers were demanding more and more speed. All the movies, all the increased data, Instagram -- all this stuff suddenly is just being loaded up, and basically, you guys were like the captain in Jaws, where he said, “We're going to need a bigger boat.” 

 

A Transcript of the script is available at the C-SPAN video page in the transcript box below the video window.

Network Neutrality - Warnings From Radio Regulation

Many of us in the public interest telecommunications sphere are excited that the FCC appears poised to reclassify Internet access, which seems a necessary first step of protecting the open Internet.

Though we often focus on the false claims of the self-interested cable and telephone lobbyists when criticizing those who oppose FCC action on this, a recent Smithsonian Magazine article is a reminder that we must be vigilant with how the FCC uses this power. Clive Thompson penned "Air Waves" for the October, 2014, issue. It offers some context from the history of radio to discuss regulation of communication technologies.

When groups like the Electronic Frontier Foundation and other pro-open Internet groups question an enhanced FCC role in protecting the open Internet, they are often motivated by the somewhat terrible record of the FCC and its precursor in balancing the speech rights of everyone vs a motivated and self-interested for-profit industry.

In 1927 Congress created the Federal Radio Commission, endowed with the power to assign wavelengths. It began aggressively doing so, booting hundreds of small stations off the air, to produce “clear channels” for the big firms—wide-open zones where they could broadcast with no interference.

Amateur time was over, as the FRC explicitly warned in a memo: “There is not room in the broadcast band for every school of thought, religious, political, social, and economic, each to have its separate broadcasting station, its mouthpiece in the ether.”

Using modern technology, there can be no doubt there is room in the broadcast for every school of thought - but we certainly have to be vigilant to ensure no current or future government agency turns the Internet into the morass of broadcast radio today. This goes both for the ways over-commercialization and consolidation has killed interesting content and the ways the FCC strictly polices some forms of offensive content (the famous seven dirty words) while ignoring blatantly racist or homophobic content. My view: the FCC should stay far from content and let households do their own filtering as necessary.

Community Broadband Media Roundup - December 12, 2014

This week in Community Broadband networks... partnerships, cooperatives, and going-it-alone. For a background in muni networks, check out this recent article from FiscalNote. The article highlights Kansas and Utah's fight for improving beyond the minimum speeds. 

Speaking of minimum, the FCC announced its new "rock bottom" for regulated broadband speeds. Ars Technica's Jon Brodkin reports that despite AT&T, Verizon, and the National Cable and Telecom Association's protests, ISPs that use government subsidies to build rural broadband networks must provide speeds of at least 10 Mbps for downloads.

Rural Americans should not be left behind those who live in big cities, the FCC announcement today said. "According to recent data, 99 percent of Americans living in urban areas have access to fixed broadband speeds of 10/1, which can accommodate more modern applications and uses. Moreover, the vast majority of urban households are able to subscribe to even faster service," the FCC said.

The FCC plans to offer nearly $1.8 billion a year to carriers willing to expand service to 5 million rural Americans. 

This is a step in the right direction, but we are alarmed to see a download:upload ratio of 10:1. People in rural areas need to upload as well as download - our comments to the FCC strongly recommended raising the upstream threshold as well and we are very disappointed to see that remain a pathetic 1 Mbps.

And, from TechDirt's own "who can you trust if you can't trust the phone company department," Karl Bode found that a study by the AT&T-funded Progressive Policy Institute concluded that if Title II regulations were passed, the nation would be "awash in $15 billion in various new Federal and State taxes and fees. Bode writes that the study cherry-picked and conflated data:

The reality the broadband industry doesn't want to acknowledge is that very little changes for it under Title II if carriers aren't engaged in bad behavior. The broadband industry is fighting Title II solely to protect potential revenues generated from abusing uncompetitive markets. That this self-serving behavior is being dressed up as concern about the size of your broadband bill is the industry's best comedic work to date.

Cities Pursuing Community Broadband

Nancy Scola reported on the growing collective of "Next Century Cities." 

[The group's] early expansion is a signal of what seems to be a shift in the way Americans are thinking about high-speed Internet access: the idea that cities will the battlegrounds for the playing out of the broadband debates. One effect of these cities working so closely with Google as it rolls out its fiber network in places like Kansas City and Austin is a realization that mayors can take broadband into their own hands -- whether that's through a municipal solution like Chattanooga's gigabit network or through partnering with traditional Internet service providers such as Comcast or Time Warner Cable.

Other partnerships are also moving muni networks forward

At the same time as the Next Century Cities announcement, the Department of Agriculture announced $190.5 million in grants and loans for rural broadband and telecommunications infrastructure.

"Modern telecommunications and broadband access is now as essential to the businesses and residents of rural America as electricity was in the 1930s," said Agriculture Secretary Tom Vilsack, in a USDA statement. The funding will go towards providing, “broadband in areas that lack it, help rural-serving public television stations begin using digital broadcasts and support other telecommunications infrastructure improvements."

Jason Meyers with LightReading explains why utility companies (like EPB in Chattanooga) are positioned so well to be home to gigabit networks.  

Several communities are considering local options for networks. Some are just in the earliest study phases: Medina County and Athens in Ohio and Walla Walla, Washington are among them. RS Fiber in Minnesota has approved its updated business plan and financial strategy, meaning it can move forward with its cooperative network, and several communities in Northeastern Oklahoma are pursuing a cooperative plan as well.

It looks like the push for local options in Colorado is having an affect on other communities. Aspen and Pitkin County have submitted requests for proposals-- perhaps inspired by Longmont, Boulder, and the rest of the communities we reported on after the November referenda.  

Meantime, Bruce Kushnick with the Huffington Post reported this week that communities all over the country have been paying for fiber infrastructure upgrades, but have seen almost none of the investment. 

Starting in 1991, the phone companies went state-to-state to get changes in state laws, known as "alternative regulations" to charge customers for the replacement of the copper wires that were part of the state-based utility, like Verizon New Jersey, with a fiber optic wire capable of 45 Mbps in both directions, the standard speed for broadband in 1992.

And though it varied by state, this fiber optic wiring was to be done everywhere -- urban, rural, and suburban, rich and poor communities and cities, and even the schools were to be wired in some states. All customers were paying for the upgrades of this future fiber optic broadband utility so they all deserved to be upgraded.

Check it out and see if your community is on the list. And if you think this isn't the first time you've heard about this Big Ripoff, you're right-- We interviewed him on Community Broadband Bits Episode 28

Net Neutrality

This week, New Jersey's Cory Booker and Maine's Angus King defended net neutrality on CNN. 

The Internet is one of the most powerful tools on the planet. Across the globe, millions of people connect every minute of every day to harness its wealth of information, exchange ideas in an open platform and foster the type of innovation and entrepreneurship that spurs economic growth.

And today, it's never been more at risk in the United States.

Washington Post's Brian Fung reported that there are hints that the telecom industry is preparing for a new Title II reclassification. Verizon's CFO Francis Shammo said, in a nutshell, that the company would do just fine if the FCC imposed the stricter regulations. 

"I mean to be real clear, I mean this does not influence the way we invest. I mean we're going to continue to invest in our networks and our platforms, both in Wireless and Wireline FiOS and where we need to. So nothing will influence that. I mean if you think about it, look, I mean we were born out of a highly regulated company, so we know how this operates.

Despite this very clear statement, we expect to see still more claims from groups like the AT&T puppet Progressive Policy Institute that Title II would somehow cause major carriers to invest even less in networks across the United States. Though, if the market were half as competitive as they claim, any firm that invested less would be in big trouble! How do we know when they are lying? Well, are their lips moving?

GAO Report Warns of Potential for ISPs to Abuse Data Caps

Last month, the U.S. Government Accountability Office (GAO) released a report warning of the possibility and potential consequences of ISPs instituting data caps in their fixed line plans. In effect, this could mean applying something like the tiered service charges based on usage levels that we see in the mobile sector to broadband connections in the home or office. But whereas the vast majority of Americans have a reasonable range of choice between several major and minor carriers for mobile service, the GAO notes that the same is not true in the market for broadband, which could lead to ISPs using data caps (or usage-based pricing (UBP) in their parlance) in various harmful ways:

...providers facing limited competition could use UBP [usage-based pricing] to increase profits, potentially resulting in negative effects, including increased prices, reductions in content accessed, and increased threats to network security.

The GAO has provided the FCC with a copy of its report, and urged that the agency take action on the issue, including systematically tracking information on how many consumers are impacted by fixed providers instituting data caps and developing a voluntary code of conduct for the industry. According to Ars Technica, the FCC has taken a skeptical stance on the issue, despite Chairman Tom Wheeler’s outspoken concerns on the lack of competition in the fixed broadband market. Pointing to the small number of consumer complaints on the issue so far, the FCC asserted that “it is unclear that any action is needed at this time.”

Usage caps do not just affect sophisticated users with bandwidth-intensive jobs or hobbies that require them to transfer large design files or generate and share multimedia content. This has the potential to affect kids and adults doing homework or taking classes online, people who hope to cut the cord from traditional television providers, and telecommuters. From the GAO study:

Participants also expressed concern about difficulty tracking the wide range of devices accessing their fixed data allowance and that fixed UBP may negatively affect students, people working from home, and those with lower socio-economic status. 

Perhaps just as importantly as the specific levels, the existence of a cap or usage-based pricing policy creates an atmosphere where people think of data as a finite resource that should be used only sparingly, even if they may not be directly affected by specific limits:

Participants exhibited confusion over data consumption—for example thinking that low-data activities like online shopping consumed large amounts of data. 

These kinds of policies are in direct contrast with the connectivity environment we should be working to create - plentiful, cheap bandwidth for as many people as possible.