Internet2 and EDUCAUSE File Reply Comments with the FCC in Business Data Services Proceeding
On May 2, 2016, the FCC released an order proposing rules that would create a new classification of services called Business Data Services (BDS). Up until this proceeding, the FCC had considered these services "special access services." In general, the FCC is trying to determine how and whether to regulate providers of BDS. The FCC is proposing to define BDS very broadly as a telecommunications service that transports data between two or more points at a rate of at least 1.5 Mbps. The proposed definition of BDS is simply too broad because it assumes that all data transport services are telecommunications services.
Given the R&E community's concerns that the FCC could mistakenly sweep R&E networks into the proceeding, Internet2 and EDUCAUSE submitted reply comments on August 9, 2016. The comments focus on three main arguments: 1) R&E networks are distinctly designed and engineered to meet the needs of a unique community of users; 2) the proposed definition of BDS is too broad because it assumes that all data transport services are telecommunications services offered directly to the public; and 3) there is no policy justification for regulating R&E networks as BDS.
Internet2 and EDUCAUSE will continue to monitor the proceeding and work with our partners in the community as we move forward.
The reply comments can be found at the following link: http://www.internet2.edu/media/medialibrary/2016/08/17/Internet2-EDUCAUSE-BDS-Comments-8-9-16.pdf.