I've worked with many regulators on industry/public reviews. Submitting opinions or copy pasta achieves nothing, no matter how voluminous. It will at best end up refered to in the final report as something like "Mupltiple unsubstantiated submissions were made supporting net neutralitity."
Things that make a difference, at least to the extent that some time and effort has to be made responding to them in the final report, include:
1. Summarising similar rulings in other jurisdictions. Ideally, including the reasoning why they made their decision, and some analysis of the impact. Comparisons of market similarities (e.g. level/structure of competition) helps to show why those decisions are relevant to the local market.
2. Arguing from local regulatory context. Working from the local competition/telecoms laws and previous decisions by the regulator, construct a structured argument why the desired outcome logically follows.
3. Arguing from first principles. Often involving some market/scenario modelling showing current market behaviour and how that would/would not change under different regulatory outcomes. Most competition/telecoms legislation is framed around benefits to consumers, so the modelling should focus on the consumer impact, not just competitor impact.
Most industry submissions will utilise a combination of the above, and draw upon global experts to strengthen their case and add credibility to their analysis.
I can't speak to the FCC and this particular ruling, but I have seen regulators change their draft recommendations on the basis of submissions received during the public review process. Even when the regulator has predetermined the outcome, having the submissions and the official responses recorded in the final report provides a reference basis for additional lobbying at a later date.
I've worked with many regulators on industry/public reviews. Submitting opinions or copy pasta achieves nothing, no matter how voluminous. It will at best end up refered to in the final report as something like "Mupltiple unsubstantiated submissions were made supporting net neutralitity."
Things that make a difference, at least to the extent that some time and effort has to be made responding to them in the final report, include:
1. Summarising similar rulings in other jurisdictions. Ideally, including the reasoning why they made their decision, and some analysis of the impact. Comparisons of market similarities (e.g. level/structure of competition) helps to show why those decisions are relevant to the local market.
2. Arguing from local regulatory context. Working from the local competition/telecoms laws and previous decisions by the regulator, construct a structured argument why the desired outcome logically follows.
3. Arguing from first principles. Often involving some market/scenario modelling showing current market behaviour and how that would/would not change under different regulatory outcomes. Most competition/telecoms legislation is framed around benefits to consumers, so the modelling should focus on the consumer impact, not just competitor impact.
Most industry submissions will utilise a combination of the above, and draw upon global experts to strengthen their case and add credibility to their analysis.
I can't speak to the FCC and this particular ruling, but I have seen regulators change their draft recommendations on the basis of submissions received during the public review process. Even when the regulator has predetermined the outcome, having the submissions and the official responses recorded in the final report provides a reference basis for additional lobbying at a later date.