December 13, 2010

Chairman Julius Genachowski
Federal Communications Commission
445 Twelfth Street, SW
Washington, DC 20554

Dear Chairman Genachowski:

On behalf of the American Institute of Biological Sciences (AIBS), I would like to express significant concern with the proposed Open Internet proposal. AIBS is a nonprofit scientific association dedicated to advancing biological research and education for the welfare of society. Founded in 1947 as a part of the National Academy of Sciences, AIBS became an independent, member-governed organization in the 1950s. AIBS is sustained by a robust membership of individual biologists and nearly 200 professional societies and scientific organizations with a combined individual membership exceeding 250,000.

Scientists and scientific organizations utilize the Internet for research, education, and outreach initiatives. For example, taxonomic biologists, environmental scientists, and natural history museums increasingly depend upon the Internet to share data and to conduct basic research. Indeed, the White House's Office of Science and Technology Policy (OSTP) has been working in recent years to develop policies and practices that would help federal science collections to make their data and resources available to the public for research, education, and informed decision-making. Moreover, natural science collections and natural history museums are actively working to digitize images of specimens and associated data such that these data may be made available to the public to advance research, education, and decision-making by governmental and non-governmental organizations. For this, the natural science community requires affordable and reliable access to the Internet. Requiring these scientific institutions, researchers, and educators to pay high fees to access to the Internet at the speeds required to conduct research could significantly hinder discovery.

The current Open Internet proposal fails to protect the interests of users, application developers, and content providers. We recommend that the Federal Communications Commission make the following changes to the proposed rule:

  • Clarify the non-discrimination rule so that it is clear what constitutes "unreasonable" and "unjust" discrimination;
  • Include a clear ban on access charges for application and content providers; and
  • Provide the same protections for wireless Internet service as for wired Internet service.

The Internet has become the central infrastructure of our times. The Federal Communications Commission must take appropriate steps to protect it and promote equal access.


Richard T. O'Grady, Ph.D.
Executive Director

Commissioner Michael J. Copps
Commissioner Robert M. McDowel
Commissioner Mignon Clyburn
Commissioner Meredith Attwell Baker

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