EFF Call for sign-ons: ISPs, networking companies and engineers opposed to FCC privacy repeal

Mark Radabaugh mark at amplex.net
Wed Mar 29 20:02:45 UTC 2017

> On Mar 29, 2017, at 9:59 AM, Joe Loiacono <jloiacon at csc.com> wrote:
> Lowering barriers to entry is where the next political focus should be.
> Joe Loiacono

And there you have much of the problem with this privacy bill.

Read the actual Report and Order:  https://apps.fcc.gov/edocs_public/attachmatch/FCC-16-148A1.pdf <https://apps.fcc.gov/edocs_public/attachmatch/FCC-16-148A1.pdf>

219 pages 

You want to start a competitive ISP these days?   Make sure you:

Incorporate your business
Obtain Liability, Workers Comp, Unemployment, Auto Insurance
Comply with the FCC Privacy Act (short reading, requires considerable investment in tracking opt in, opt out, privacy policies)
File the mandatory FCC 477 filings twice a year with detailed information on the geolocation of all of your customers and service area.
If offering VoIP service file your 499-A and Quarterly 499-Q’s with the FCC
Draft your “Open Internet Disclosure Statement”, pay a FCC lawyer a couple grand to renew it, make sure it’s prominent on your website
Build your website
Obtain bandwidth and IP, fill out your ARIN information.
Make up your “Consumer Label” for Broadband: https://www.fcc.gov/consumers/guides/consumer-labels-broadband-services <https://www.fcc.gov/consumers/guides/consumer-labels-broadband-services>  (probably need a lawyer for this too..)
Pay the lawyer to write your “Terms of Service” so that you have at least some chance of surviving the lawsuits
Implement your CALEA plan and file that paperwork with the FBI so they can find you
Register with the Copyright office so that you can deal with DMCA notices.  
Establish your copyright policy and procedures.  Have your lawyer review it.
Make sure you comply with 18 USC 2258A regarding reporting and registration for kiddie porn, train your employees
Make sure you have a CPNI policy, training, and report to the FCC yearly
Implement and file your Section 255 “Disability Rights” policy and make sure you file yearly with the FCC your information

Slap up a Ubiquiti access point and you can now make millions of dollars in short order.

I’m sure I forgot a few things like “build your network”, but that’s simple.


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