Public Policy Manager, Telefónica.
Telefónica is fully committed with an Open Internet, not only pushing for it through our Digital Manifesto, but also taking action as needed. On July, we filed our views in response to the Commission’s Notice of Proposed Rulemaking on Protecting and Promoting the Open Internet. On the 15th of September Telefónica also submitted additional reply comments focusing on a short number of important subjects that make part of this debate.
We believe that any regulation adopted in the US on Internet will have a far reaching influence worldwide, and is deem to affect Regulatory or Policy initiatives in Europe and Latin America, the regions where Telefónica operates. For this reason we have submitted our views to the FCC proceeding through a publicly available document.
Fully acknowledging the relevance of the Internet and how will continue to shape our lives, we are convinced that protecting an Open Internet will be best secured when:
• Consumers have choice amongst different commercial options to decide the way they want to experience the services and applications.
• Innovation can take place everywhere and a wider offer of innovative Internet services can flourish as a result, including any forms of joint responses of the network and the edge providers to the diversity of user needs.
• Regulation does not prevent the development of the Internet. Given the dynamic and innovative nature of the Internet, relying on principles rather than detailed rules is the best way to preserve openness of the Internet.
Furthermore, we encourage the FCC to: , :
• Keep transparency and no-blocking rules as cornerstones to ensure the Openness of the Internet
• Keep a flexible approach to reasonable commercial arrangements between network and Internet providers
• Provide the flexibility to keep in mind the particularities of mobile Internet.
On a different note, we recalled the FCC challenges to openness do not come mainly from broadband network but from other areas of Internet ecosystem and suggests to the FCC to take this fact in due consideration in order to achieve a level playing field across the Internet value chain.
More recently, the document of reply comments submitted to the FCC in September insist on the harmful effects that a heavy Open Internet regulation would have on the future of Internet and in particular on the needs of an adequate and flexible policy framework for Internet mobile services due to its technical constraints and because mobile broadband services are rapidly developing from infancy. We also address the discussion on “zero rated offers”, which are in our view clear examples of commercial innovation that brings direct benefits to consumers and which should be seen as fully compatible with the goal of the Open Internet.
The Internet has changed and has still a huge potential to be realized if the rules are flexible enough. Accordingly, we appraise that FCC proposal gives an opportunity to achieve a good balance between preserving Internet Openness and allowing the commercial flexibility required to support subsequent waves of innovation for the benefit of consumers.
The debate will became hotter and hotter in the coming months in US, so stay alert as we may get relevant updates through specialised media.
