On May 15, 2014, the Federal Communications Commission (FTC) released a "Notice of Proposed Rulemaking" and opened the topic for comment. NCISS supports a free and open Internet without preferred customers or tiered pricing. Consequently, the NCISS Legislative Advocates at Lobbyit filed the comments below from President Bob Heales on behalf of NCISS members.
The full text of the FCC proposal can be found here:
FCC proposal for Protecting and Promoting the Open Internet
The text of the comments sent to the FCC follow:
"The National Council of Investigative and Security Services (NCISS) hereby submits this comment regarding Federal Communications Commission (FCC) proceeding 14-28, "Protecting and Promoting the Open Internet", opened May 20, 2014.
We greatly appreciate this opportunity to provide our input on the matter. NCISS is a trade association representing private investigators and private security service companies from across the United States. NCISS is comprised 1000 members, the majority of which are private investigators located in every State of our Union. Together with security service providers, NCISS represents well in excess of 100,000 security and investigative professionals, who generate over $2.5 billion in economic activity per annum.
Private investigators are an integral component of the legal system. For private investigators, access to information is the key to our operation and success, and undoubtedly, the Internet is the overwhelmingly preferred avenue for obtaining a wide variety of crucial information. Whether tracking lost heirs, searching for missing or abducted children, uncovering hidden assets, locating witnesses for civil or criminal matters, conducting due diligence for mergers and acquisitions, or proving financial crimes or instances of fraud, private investigators rely on the Internet for timely access to information. With so many government entities and agencies, from the townships and villages to the state and Federal levels, making the majority of information publicly available on the Internet, The FCC cannot (even if inadvertently) restrict the ability of private citizens to access such information by allowing the bifurcation of the Internet and relegating such non-commercial sites and pursuits to second-class status. To do so would doom our ability to act quickly and accurately, often when human life is at stake.
Please do not take regulatory action which would allow for "tiered" services on the Internet, allowing providers to increase speeds for preferred customers. Internet users who do not have the commercial clout to pay more for enhanced service could ultimately pay a steep price for the change as providers who see less commercial benefit from such users deny them crucial technological advances. We do not believe this result is inconceivable, and in fact believe it would be likely in the long run as providers seek to maximize their profits and focus more on developing technology and improving services for those simply with the ability to pay more. For private investigators, the vast majority of whom are small businesses or solo practitioners, such a change could be fatal to our ability to access critical information.
We respectfully ask that you preserve true equality in Internet services for all users, and not let large commercial operations gain an unfair advantage."
Respectfully,
Robert Heales, President
National Council of Investigative and Security Services
Robert Heales President
National Council of Investigative and Security Services
7501 Sparrows Point Blvd. Baltimore
MD 21219 800-445-8408 Fax: 410-388-9746
E-Mail: nciss@comcast.net
www.nciss.org
