> The program is partnering with carriers to give away access to Wikipedia (although no money is exchanged between the carrier and Wikipedia). It doesn't sound like it avoids NN issues. Giving away access to a certain website.. sounds exactly like an NN issue.

> And I don't think Wikipedia's competitors would think this "keeps the playing field level" either. How would they compete against Wikipedia, when their users have to pay to access their service, but dont have to pay to access wikipedia?

I disagree for two reasons:

• First, as a matter of general principle I prefer to minimize overlap of different regulatory frameworks. We have a general framework for dealing with anticompetitive actions and practices--antitrust law. If for some reason antitrust law cannot deal with competition issues that zero rating Wikipedia cause, let's beef up antitrust law to deal with it.

Same goes for some other areas that are often included in net neutrality, such as privacy and transparency. I don't want a separate law for these things for each kind of business. They are general things that should be independent of type of business.

(I'm open to arguments that it is politically impossible to get a good general privacy law, for instance, passed and so we may have to settle for doing these things on a type of business by type of businesses basis in things like net neutrality regulations).

• Second, most of what an ISP could accomplish with zero rating could be accomplished by other means that would be less efficient but not use the internet (and so completely avoid any possibility of net neutrality issues), but would have largely the same impact on consumers.

For example, suppose Comcast decided to offer a streaming music service of their own, and decided to zero rate it. There are a couple ways they could do this. Before listing them, though, a brief overview of how cable internet works.

The cable that comes into your house has something like 2 GHz of bandwidth. Comcast divides this into about 300 separate channels with 6 MHz of bandwidth each. In the old days, these low level 6 MHz channels carried analog TV signals, but nowadays they carry digital streams. Each of these digital streams is divided into several sub-streams all multiplexed onto the low level 6 MHz stream. They build all their services on top of those streams and sub-streams. Internet service is provided by combining several streams (enough to support your download speed) and running IP on top of that, with another low level stream used for upload.

The key point here is that Comcast has a bunch of data steams into and out of your house that are running a lower level protocol than IP.

So how could Comcast offer a streaming music service, designed to be playable on any device that you put on your home Comcast network?

1. They could simply run it on the web, and users access it over the internet.

2. They could run it at a lower level, running it on a sub-channel of one of their low level 6 MHz channels, with an app on their set-top boxes to interface to it. The app could make the music and control interface available on the LAN (wired and/or wifi) via a simple web server running on the set-top box.

Note that with #2, there is no internet involved. The music starts on Comcast's internal network, and is transported to your LAN over a layer that is lower level than IP, where it is served on the LAN.

But note that from a user point of view, these two are pretty much the same. In both cases to play Comcast streaming music on your home devices you go to a website which streams them to you. In #1 that website happens to be off your LAN, and in #2 it is on your LAN.

It makes no sense to me to say that in case #1 Comcast cannot provide the service at no extra charge, but that in case #2 they can.

I think net neutrality should be simple:

• Your ISP must provide the speed and bandwidth promised, for the price promised. You can use up to the promised bandwidth, for anything you see fit and you will get the promised speed, without blocking or throttling, except if the ISP is legally required.

That's pretty much it. Everything else should be covered by other more general regulations (antitrust, consumer protection).