November 30, 2017

Our Response to Concerns Raised About Our Analysis of the FCC’s Net Neutrality Public Comments

By Lee Rainie

Pew Research Center released a report on Nov. 29 analyzing the 21.7 million comments submitted online during the U.S. Federal Communications Commission’s open public comment period on net neutrality.

Fight for the Future has raised concerns about some aspects of our report, two of which point out inaccuracies that do not change the overall findings of the study. We believe, however, that Fight for the Future’s other points mischaracterize our report and our nonpartisan, non-advocacy mission.

The first correction we have made concerns the total number of comments made during a 2014 FCC campaign to solicit public views on net neutrality. The initial number we published took into account the FCC’s initial comment period, not comments from a second comment period. We have corrected that error and noted it in our report.

A second correction concerns our assertion that John Oliver promoted the most common pro-net-neutrality comment to have been submitted to the FCC in its 2017 campaign to solicit public views on net neutrality. That reference was also inaccurate. It, too, has been corrected and is noted in our report.

Fight for the Future argues that our report claims “the large bulk of the comments came from a small number of organizations.” The report in fact states that “the text of many of the top comments can be traced back to a small number of organizations.” In this context, the phrase “small number of organizations” refers to the primary organizations on whose websites the text of those comments appeared. We used the term “organization” because it is a generally understood and value-neutral term. We would use the same phrasing to describe any trade association or public-interest group comprising multiple member organizations.

Fight for the Future also alleged that our report offered judgment on what constitutes a legitimate comment and what does not. We took pains in the report to not question the validity of any specific individual comments or question the validity of bulk filing of comments. As an example of this, we note in our report that there is not “anything inherently wrong or sinister about bulk filing of comments. This analysis simply highlights the scale at which digital tools are being brought to bear in the long-standing practice of commenting on proposed government rules.” Although we highlighted certain difficulties in interpreting the source and meaning of some comments, we did not make any claims about what constitutes a legitimate comment or a legitimate commenter.

We are a nonpartisan and non-advocacy organization. We do not take policy positions on issues. Therefore, our analysis did not seek to promote either side of the net neutrality debate. Instead, the analysis sought to highlight the ways in which individuals and groups are using modern digital tools to engage in the long-standing practice of speaking out in order to influence government policy decisions.