FCC Net Neutrality Online Public Comments Contain Many Inaccuracies and Duplicates

correction : This report card initially noted that 450,000 comments were submitted to the FCC during its previous open comment period on net disinterest. That data point was based lone on the initial comment period, spanning Feb. 9-July 18, 2014. The FCC subsequently reopened the comment time period through Sept. 15, 2014, and the report now reflects the total number of comments received during the entirety of the 2014 public comment period. In accession, a reference to John Oliver in a sentence referring to the most popular pro-net-neutrality gloss has been removed. Pew Research Center has issued a instruction regarding concerns raised about this psychoanalysis .
For the second clock time in less than four years, the U.S. Federal Communications Commission ( FCC ) is considering regulations regarding net neutrality – the principle that internet service providers must treat all data the same, careless of the origin or function of that datum. Opponents of net neutrality regulations argue that ISPs should have the right to prioritize traffic and appoint for their services as they wish. interim, supporters of final neutrality suggest that alleged fast lanes are anti-competitive and would prevent start-ups and smaller companies from competing with more well-established companies that can afford to pay for prioritize world wide web traffic .
From April 27 to Aug. 30, 2017, the FCC allowed members of the public to formally submit comments on the national. In full, 21.7 million comments were submitted electronically and posted on-line for review. This figure dwarfs the number received during the initial comment menstruation when the FCC last accepted comments on this topic in 2014, a well as the closely four million entire submissions received during the entirety of the gossip process that class. net disinterest regulations underpin the digital lives of many Americans, yet it is challenging to review the public on such an inherently complex and technical subject. For this reason, Pew Research Center set out to analyze the opinions of those who had taken the time to submit their thoughts to the FCC .
however, the Center ’ randomness analysis of these submissions finds that the comments confront challenges to anyone hoping to understand the attitudes of the concern public regarding net neutrality. It besides highlights the ways in which individuals and groups are using modern digital tools to engage in the long-standing drill of speaking out in order to influence government policy decisions. Among the most luminary findings :

  • Many submissions seemed to include false or misleading personal information. Some 57% of the comments utilized either duplicate email addresses or temporary email addresses created with the intention of being used for a short period of time and then discarded. In addition, many individual names appeared thousands of times in the submissions. As a result, it is often difficult to determine if any given comment came from a specific citizen or from an unknown person (or entity) submitting multiple comments using unverified names and email addresses.
  • There is clear evidence of organized campaigns to flood the comments with repeated messages. Of the 21.7 million comments posted, 6% were unique. The other 94% were submitted multiple times – in some cases, hundreds of thousands of times. In fact, the seven most-submitted comments (six of which argued against net neutrality regulations) comprise 38% of all the submissions over the four-month comment period.
  • Often, thousands of comments were submitted at precisely the same moment. On nine different occasions, more than 75,000 comments were submitted at the very same second – often including identical or highly similar comments. Three of these nine instances featured variations of a popular pro-net-neutrality message, while the others promoted several different anti-net-neutrality statements.

The Center conducted its analysis by downloading all the comments from the FCC ’ s publicly available API. All data and comments used in this report are stored on the FCC ’ s web site and are freely available to the public. Researchers then used respective data analysis techniques to summarize the comments and to look for duplicates or invalid information. Most notably, the Center utilized a bill of textual similarity to determine the plowshare of highly exchangeable comments that were submitted multiple times. Full details of the contents of this dataset and the techniques used in this analysis can be found in the methodology at the end of this reputation .

Many submissions contained false or misleading personal information

Collecting large-scale data from the public is always challenging. It is unmanageable to ensure that a person on-line is indeed who they claim to be, and disproof of person ’ s personal information can be accomplished with relatively minimal feat. The Center ’ mho analysis finds evidence that many people did not reveal their true identities when submitting comments to the FCC. Some of these instances may have been accidental, but in many cases patterns in the comments indicate those submitting the comments intentionally entered false or mislead personal information .
The most coarse “ name ” included as an author was not, in fact, a name. In closely 17,000 instances, the name of the commenter filing their views on the FCC site was written as “ net neutrality ” ( this term besides appeared as the author of more than 5,000 comments in lower-case form ). “ The Internet ” besides appeared as the appoint in about 7,500 submissions. Of the circus tent 15 names that appeared in the FCC submissions, eight included the common last names of “ Smith ” or “ Johnson, ” and four were not names at all .

In hypothesis, the process for submitting a comment to the FCC included a establishment technique to ensure the e-mail address submitted with each gloss came from a legitimate report. The submission form clearly states that all data submitted, including names and addresses, would be publicly available via the FCC web site .
however, the Center ’ south analysis shows that the FCC site does not appear to have utilized this e-mail verification action on a consistent footing. According to this analysis of the data from the FCC, only 3 % of the comments definitively went through this validation work. In the huge majority of cases, it is unclear whether any attack was made to validate the e-mail address provided .
As a consequence, in many cases commenters were able to use generic or bogus e-mail addresses and still have their comments accepted by the FCC and posted on-line. For exemplify, the e-mail address exemplar @ example.com appeared in 7,513 comments, making it the most park electronic mail address to appear. The e-mail address john_oliver @ yahoo.com ( television receiver host John Oliver advocated on his read for net neutrality earlier this year ) was besides used in 1,002 comments. All told, the Center ’ mho analysis identified 1.4 million electronic mail addresses that appeared multiple times in the comments .
additionally, in 9,190 cases the electronic mail address supplied did not contain the “ @ ” character necessary to serve as a function electronic mail account. furthermore, 10 % of the comments submitted did not include an electronic mail savoir-faire at all .
Along with using duplicate or potentially deceitful addresses, the Center ’ sulfur analysis finds more than 8 million submissions included electronic mail addresses from impermanent e-mail accounts designed to disappear within hours and leave no trace of electronic mail exchanges behind. Taken together, some 57 % of the comments submitted to the FCC either utilized a impermanent electronic mail address or an e-mail address that was besides included with at least one other gloss .
The Center ’ s analysis of these data suggests the net neutrality comment period was marked by respective organized efforts aimed at conveying the populace ’ sulfur feelings on this subject .
This analysis finds that 6 % of the 21.7 million comments were submitted a one fourth dimension. The remaining 94 % were each submitted multiple times, in some cases numbering in the thousands. In fact, five comments were submitted more than 800,000 times each. Taken together, these seven comments alone account for more than 8 million submissions, representing 38 % of the entire over the entirety of the remark time period .
The individual comment submitted more times than any other was a pro-net-neutrality statement that appeared 2.8 million times, accounting for 13 % of all submissions. At the like time, seven of the top 10 comments argued against net neutrality and encouraged the FCC to roll back Title II regulations. The seven most-popular anti-net-neutrality posts made up 27 % of all the comments submitted, while the three most-popular comments in prefer of net neutrality made up 17 % of the full submitted .
Whether they argued for or against net income neutrality, the text of many of the acme comments can be traced spinal column to a small number of organizations. For example, the single most-popular remark was a pro-net-neutrality argument that appeared as a submission form on the web site battleforthenet.com. similarly, the wording for three popular comments opposing net neutrality ( representing the second-, sixth- and ninth-most submitted overall ) appeared on the web site for an organization known as the Taxpayers Protection Alliance. Combined, the textbook from these three suggested comments appeared in about 2.4 million submissions, making up 11 % of the total .
other research has suggested that some plowshare of the FCC comments may have been submitted in bulk using automated processes, such as organized bot campaigns. The Center ’ second psychoanalysis finds confirm for this argument, based on the fact that many comments were submitted at precisely the same moment. The FCC assigned a accurate timestamp to each remark as it was submitted, and an analysis of those timestamps shows that on numerous occasions, thousands of posts were submitted at precisely the lapp clock – a sign that these submissions were likely automated.

On more than 100 different occasions, 25,000 or more comments were submitted to the FCC at the same accurate second base. And on nine different occasions, 75,000 messages or more were posted simultaneously. The three most numerous of these nine moments have variations of the most popular pro-net-neutrality message. The remaining six admit respective different anti-net-neutrality statements .
In the most fecund example, 475,482 comments were submitted on July 19 at precisely 2:57:15 post meridiem EDT. Almost all of those comments were pro-net neutrality and offered variations of text that appeared on the locate battleforthenet.com. In some cases, the entirely deviation was the diagnose of the submitter : the like text was “ signed ” 286 times by “ Andrew, ” 265 times by “ Michael ” and 235 times by “ Ryan, ” among other names .
A deeper analysis of these coincident comments highlights several variations in how they were submitted. In some cases, the comments were highly similar but with minor variations. The 86,237 comments submitted at precisely 7:18:04 post meridiem on May 24 offer an model of this approach. No two were precisely the lapp, but all featured consistent patterns. Most began with variations of a alike composition, such as : “ Dear [ FCC Chairman ] Mr. Pai, I am a voter worried about regulations on the Internet, ” “ Dear Chairman Pai, I am a voter worried about Title 2 and net disinterest, ” or “ lamb Commissioners : I ’ thousand concerned about Internet regulation and web neutrality. ”
The body of these comments besides featured similar phrases. One post charged, “ Obama ’ s policy to take over the web is a betrayal of net neutrality. It reversed a free-market policy that functioned supremely well for decades with both parties ’ backing. ” While another stated, “ The former administration ’ south policy to control the Internet is a treachery of the open Internet. It disrupted a free-market organization that functioned fabulously smoothly for decades with bipartisan approval. ”
In other cases, the subject of these coincident submissions was entirely identical. On May 28 at precisely 8:23:51 post meridiem EDT, the FCC received 90,458 comments with this demand message : “ Title II is a Depression-era regulative framework designed for a telephone monopoly that no longer exists. It was wrong to apply it to the Internet and the FCC should repeal it and go back to the free-market access that worked therefore well. ” indeed, this model was not an sequester incidental. The Center identified at least five divide occasions when the claim lapp text was submitted more than 24,000 times at precisely the like moment .

Off-topic comments

Some comments submitted to the FCC had nothing to do with net disinterest and appeared to be attempts by users to further complicate the data collection :
• At least 34 comments included references to Bee Movie, some of which contained portions of the movie ’ south script.
• Fully 108 comments had more non-alphanumeric characters – such as equal signs ( = ) or ampersands ( & ) – than alphanumeric characters.
• Others consisted wholly of shortstop messages without a clean meaning, such as : “ get a hobby, ” “ Democracy, ” “ computerized tomography video, ” “ google it, ” “ SAD ! ” and “ ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ”
Of course, the fact that many comments were submitted at precisely the same time does not mean the organization or web page where the text first gear appeared was responsible for automating or standardizing those submissions. It is possible a third party used the text and submitted these comments on its own. Nor is there anything inherently wrong or sinister about bulk filing of comments. This analysis just highlights the scale at which digital tools are being brought to bear in the long-standing practice of commenting on project government rules .
During the four-month period in which the FCC accepted comments on net neutrality, an average of 172,246 posts were submitted per day. But the comment period featured respective long stretches with few submissions, punctuated by bursts of intense activeness .
The gossip period formally opened on April 27, and lone 453 comments were submitted on that day. On Sunday, May 7, two major events occurred that coincided with a significant increase in submissions. That evening, comedian John Oliver broadcasted a about 20-minute section on his HBO read last Week Tonight defending net neutrality and encouraging his viewers to submit comments supporting his stead. The final clock the FCC considered net neutrality in 2014, a Pew Research Center analysis showed that John Oliver ’ second program besides led to a transfix in the number of comments submitted .
besides on May 7, the FCC issued a newsworthiness release stating that a distributed denial of service attack ( DDoS ) occurred against the electronic filing system. Some critics have questioned whether an actual DDoS attack occurred, noting that the FCC did not provide software documentation regarding the attack following a Freedom of Information Act request by the web site Gizmodo. And two democratic members of the House Energy and Commerce Committee have since requested an investigation into the matter .
More than 2.1 million comments were submitted in the five days following those two events ( May 8-12 ). Those comments made up 10 % of all the comments submitted during the entire meekness period .
In answer to this tide of submissions, the FCC released a public notice on May 11 that announced a “ sunlight time period ” for the week cross May 12-18 in which the FCC would temporarily stop taking public comments due to the large number of submissions. According to the FCC ’ s statement :
“ This means that during this brief menstruation of fourth dimension, members of the public can not make presentations to FCC employees who are working on the topic, and are probable to be involved in making a decisiveness on it, if the underlying content of the communication concerns the result of the go … The Commission adopted these rules to provide FCC decision-makers with a time period of recumb during which they can reflect on the approaching items. ”

Although the FCC claimed it would not accept comments during this period, the Center ’ mho psychoanalysis finds that more than 93,000 posts submitted on those days were included among the final examination database made available for public review .
The pace of comments slowed significantly over the future few weeks. From May 30 to July 8, the number of comments declined to an average of entirely 5,832 posts per day. In mid-july, activity increased dramatically and remained relatively high until the original date the comment period ended .
The unmarried day with the most submissions occurred on July 12. on-line activists dubbed the day “ final Neutrality Day of Action ” or “ Day of Action to Save Net Neutrality ” and numerous sites altered their websites to include statements favoring net income disinterest. On that day alone, 1.4 million comments were submitted electronically to the FCC .

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