98.5% of unique net neutrality comments oppose Ajit Pai’s anti-Title II plan

A study funded by Internet service providers has found something that Internet service providers really won't like.

The overwhelming majority of people who wrote unique comments to the Federal Communications Commission want the FCC to keep its current net neutrality rules and classification of ISPs as common carriers under Title II of the Communications Act, according to the study released today.

The study (available here) was conducted by consulting firm Emprata and funded by Broadband for America, whose members include AT&T, CenturyLink, Charter, CTIA-The Wireless Association, Comcast, NCTA–The Internet & Television Association, the Telecommunications Industry Association (TIA), and USTelecom.

Unique comments support current rules

When Emprata analyzed all 21.8 million comments, including spam and form letters, 60 percent were against FCC Chairman Ajit Pai's plan to repeal the Title II classification, and 39 percent supported the repeal plan. But the numbers shifted starkly in favor of keeping the Title II rules when excluding spam and form letters in order to analyze just unique comments written by individuals.

Emprata wrote:

[T]here are considerably more "personalized" comments (appearing only once in the docket) against repeal (1.52 million) versus 23,000 for repeal. Presumably, these comments originated from individuals that took the time to type a personalized comment. Although these comments represent less than 10 percent of the total, this is a notable difference.
That amounts to 98.5 percent of personalized comments supporting the current rules.

Form letters constitute the majority of comments on both sides. This was especially pronounced in the case of anti-Title II comments:

The overwhelming majority of comments for and against repealing Title II are form letters (pre-generated portions of text) that appear multiple times in the docket. The form letters likely originated from numerous sources organized by groups that were for or against the repeal of Title II. Form letters comprise upwards of 89.8 percent of comments against Title II repeal and upwards of 99.6 percent of the comments for Title II repeal.
Group that funded study opposes Title II rules

Emprata said that it was contracted by Broadband for America "to perform an independent and unbiased analysis of the comment data received by the FCC in response" and that Emprata itself "does not have a vested interest in whether Title II is repealed or not."

Broadband for America provided a link to the study on its homepage. The statement on the group's homepage today did not mention the public's broad opposition to repealing Title II net neutrality rules, saying only that the "report by expert data analytics firm reveals unprecedented volume and clutter in the docket."

Broadband for America's homepage advocates for overturning the rules, saying that "Repealing Title II utility Regulations Will Strengthen the Internet—utility regulations deter investment in networks and put Internet jobs at risk."

ISPs support net neutrality despite their stance against using the FCC's Title II authority to enforce net neutrality rules, the group says.

"Internet providers practice net neutrality today and they always will. They even put it in writing," the group said. While the NCTA cable lobby group posted a full-page ad in The Washington Post saying they won't block or throttle Internet content, the group's members did not put that pledge into binding contracts with customers.

The NCTA recently conducted a survey that found strong public support for net neutrality rules.

Former FCC official Gigi Sohn, who played a role in crafting the current rules, tweeted that the FCC "needs to do its own analysis of net neutrality comments, not rely on [a] study funded by Comcast, AT&T, and the broadband industry."

Fake e-mails and duplicate comments

The Emprata study shed more light on comments from artificial e-mail domains and international addresses. Comments from fake e-mails generally opposed Pai's plan to overturn the Title II common carrier classification.

"More than 7.75 million comments... appear to have been generated by self-described 'temporary' and 'disposable' e-mail domains attributed to FakeMailGenerator.com and with nearly identical language," Emprata wrote. "Virtually all of those comments oppose repealing Title II. Assuming that comments submitted from these e-mail domains are illegitimate, sentiment favors repeal of Title II (61 percent for, 38 percent against)."

There were 9.93 million duplicate comments from submitters listing the same physical address and e-mail. "This was more prevalent in comments against repeal of Title II (accounting for 82 percent of the total duplicates), with a majority of duplicate comments associated with e-mail domains from FakeMailGenerator.com," Emprata wrote.

There were also 1.72 million comments with non-US home addresses, and nearly all of those (99.4 percent) oppose repealing the Title II classification, the study noted.

As we've previously reported, the net neutrality docket appears to have been targeted by numerous spam bots that falsely attribute comments to people whose names and addresses were pulled from data breaches.