Analysis Comcast has barreled into the fight over net neutrality by arguing that the current rules impose "onerous" regulations and "substantial costs that undermine investment."
The filing [PDF] to the FCC – America's broadband watchdog – comes a day after internet giants Google, Facebook, Amazon and others argued through the Internet Association that the regulator's plan to scrap its own Open Internet Order would "create significant uncertainty" and "harm consumers and innovators alike."
The uncertainty comes from the new rules, Comcast argues, and getting back to the old way of doing things would be better for everyone.
And just as the Internet Association supplied a 45‑page economic analysis that argued net neutrality not only didn't harm investment but actively grew the broader cloud market, Comcast has provided its own economic analysis that argues the opposite.
That economic analysis, it must be said, reads more like a policy document than an objective study. At the same time, it argues that a regulator "must perform proper economic market analysis" as a way of attacking the FCC's existing net neutrality rules, but there is virtually no actual economic analysis in the document.
It's been so long since Washington lobbyists (and politicians) have actually seen a proper economic analysis, it makes you wonder whether any of them remember what they look like.
As for this "economic analysis," it concludes: "The bottom line is that the FCC can achieve its goals for an open Internet without importing the archaic principles and onerous restrictions embedded in Title II that stifle investment and innovation and cause job losses."
Meanwhile, as the internet giants argue that the imposition of the rules is essential to protect the much-larger internet ecosystem, Comcast – as one of the biggest companies that allows users to actually connect to that system – comes at it from a completely different direction.
It argues that the huge explosion in the internet market came about because there was "light touch" regulation. As such, imposing "Title II" classification – which is what the Open Internet Order does in order to give it a legal foundation – risks damaging what is a really good system.
"As Chairman Pai recently put it, this bipartisan, light-touch approach 'wasn't controversial'," notes Comcast's filing, "It was the 'consensus' for two decades and it paved the way for the private sector to invest in networks to the tune of $1.5 trillion."
The Title II classification, it argues, is "an unfortunate, unnecessary, and profoundly unwise wrong-turn for the broadband economy and consumers more broadly."
Of course, these arguments omit what has been a decade of argument over net neutrality and both Comcast and Pai know that they are being willfully blind to reality when they effectively argue "if it ain't broke, don't fix it."
There is a reason why people started pushing for these rules, and that's because cable companies started using their unique position to try to control access to people, in return for – you guessed it – money. It's not like people made up the idea of cable companies limiting or restricting access to content – the net neutrality movement was born precisely because cable companies started doing it.
And the argument that light touch has been the way for 20 years makes the ridiculous assumption that nothing has really changed with respect to the internet since 1997. But it has – and the absolute biggest change in the cable companies' minds is that broadband speeds have now made the transmission of high-resolution video extremely easy.
People no longer need the cable companies' TV bundles – they can go direct to the supplier through an app or a website. And that risks creating an enormous hole in Big Cable's profits.
And if you have any doubt, consider this: Comcast routinely offers millions of its users internet access and a TV bundle for less money than just the internet access on its own. And it does it through a wide variety of time-based "discounts" if you agree to be locked into a contract.