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Before theFederal Communications CommissionWashington, D.C. 20554In the Matter of ))Framework for Broadband Internet Services ) GN Docket No. 10-127)
Reply Comments of the Writers Guild of America, West, Inc. (WGAW)
David J. YoungExecutive DirectorWriters Guild of America, West, Inc.7000 West Third StreetLos Angeles, CA 90048(323) 782-4689August 12, 2010
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Introduction
Writers Guild of America, West, Inc. (WGAW or Guild) submits the following replycomments in response to issues raised by other filers in the matter of the FederalCommunications Commission’s (FCC) June 17, 2010 Notice of Inquiry (NOI), GN Docket No.10-127. The WGAW would like to take this opportunity to respond to arguments raised by theMotion Picture Association of America (MPAA), and a group of entertainment industry unionsincluding the American Federation of Television and Radio Artists (AFTRA), the Screen ActorsGuild (SAG), the Directors Guild of America (DGA) and the International Alliance of TheatricalStage Employees (IATSE, collectively, “Industry Guilds”).The WGAW is a labor organization representing 8,000 professional writers of television,film, news, and new media productions and has a collective bargaining relationship with themember companies of the MPAA. AFTRA, SAG, IATSE and DGA are also labor organizationsthat have collective bargaining relationships with the employer members of the MPAA.
Protecting a Free and Open Internet is Critical to the Promotion of Diverse andIndependent Content
As the WGAW has stated in earlier filings with the Commission on the NationalBroadband Plan and Preserving an Open Internet/Broadband Industry Practices, network neutrality is essential to our democratic society. As the Internet has become the town square of the 21
st
century, nondiscriminatory access to diverse and independent news, information andentertainment sources on this platform is necessary for the free exchange of ideas. In addition,the low barriers of entry online and limitless distribution opportunities of the Internet promise tospur competition across many industries, including entertainment. The result is a diverse and
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growing range of services, content and applications. Consumers benefit from the increasedchoice created by the competitive forces of an open Internet.Guild members benefit from an open Internet both as content creators and consumers,who write and view news, commentary and entertainment, and participate in social networking.In addition to the benefits Internet freedom offers to our society, for content creators the Internetalso represents an independent and competitive distribution platform. While television and filmdistribution is controlled by a handful of powerful media companies, the Internet offers amedium through which anyone with a story can find an audience. An open Internet protected bynet neutrality will enhance job opportunities for Guild members and expand content offerings toconsumers.
Opposition to Common Carrier Status, is, in Effect, Opposition to Net Neutrality
As outlined in our initial comments on this NOI and discussed in the separate submissionof the Open Internet Coalition, the recent DC Circuit decision
Comcast v. FCC
makes clear thatthe Commission will be unable to protect a free and open Internet by relying on Title I ancillaryauthority. It is therefore necessary for the FCC to reclassify broadband transmission as a“telecommunications service” subject to regulation under Title II in order to enforce netneutrality. We respectfully disagree with the Industry Guilds that a “non-common carrierapproach” will allow the Internet to remain “a free and open platform that promotes innovation,investment, competition, and users’ interests.”
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Further attempts by the Commission to rely onancillary authority under Title I to protect a free and open Internet will inevitably be met withcontinued legal resistance and will prolong regulatory uncertainty.
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See Comments of AFTRA, et al., In the Matter of a Framework for Broadband Internet Services, GN Docket No.10-127, p. 9.
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