If you're hoping to keep strong net neutrality rules on the books, a former Federal Communications Commission official has some advice for writing a great comment to the FCC.

Gigi Sohn was a top counselor to former FCC Chairman Tom Wheeler when the commission reclassified ISPs as common carriers and imposed net neutrality rules against blocking, throttling, and paid prioritization. Yesterday, she published a post on Mashable titled "4 steps to writing an impactful net neutrality comment (which you should do)." Even if the FCC repeals net neutrality rules, meaningful comments could help net neutrality advocates argue in a future court case that the rules should be reinstated, she wrote.

Before joining the FCC, Sohn was president and co-founder of the advocacy group Public Knowledge, which still plays an active role supporting net neutrality rules and other consumer protection regulations. She left the FCC after the election of President Donald Trump and took fellowship positions with Georgetown Law's Institute for Technology Law & Policy, Open Society Foundations, and Mozilla.

Write about how the rules affect you

First, Sohn says you should "write about yourself and how the net neutrality rules have affected you."

"Maybe you are an entrepreneur who sells craft chocolates and coffee and could never compete if Godiva and Starbucks paid [ISPs] for faster carriage," Sohn wrote. "Perhaps you sell crafts on Etsy, which would never have caught the public's eye if ISPs could favor Amazon or eBay for any reason. Maybe you own a local alarm company that would not survive had AT&T and Comcast been allowed to favor their own alarm systems over yours."

This advice can apply even if you don't operate an online business. "Has Facebook or Skype connected you with long lost friends and family? Were you able to complete a high school, college, or graduate degree over the Internet? Has Internet access improved your quality of life in any significant way? If you believe those benefits would be lost should ISPs be able to pick winners and losers on the Internet, say so," she wrote.

What is broadband, anyway?

Secondly, commenters should "Write about what you understand you are buying when you purchase broadband Internet access." That's because the repeal of net neutrality rules depends on the FCC reclassifying broadband as an "information service" instead of a "telecommunications service."

"For the FCC to reverse its 2015 determination that broadband ISPs are 'telecommunications services' subject to greater oversight under Title II, it must show that ISPs are offering, and you understand that you are buying, not just a fast on-ramp to the Internet, but a bundle of 'information services,' like e-mail, cloud storage, and other proprietary over-the-top services," Sohn wrote.

"Tell the FCC why you buy Internet access," she continued. "Is it to get an e-mail address, cloud storage, or other online services from that specific provider? Or is it to get reliable access to all the Internet offers at fast speeds? Tell the FCC if you get e-mail, cloud storage, Web hosting, and other over-the-top services from someone other than your ISP. If you've received a solicitation from an ISP, scan and attach it to your comments or quote what it says."

One thing Sohn didn't mention is that FCC Chairman Ajit Pai's proposal argues that ISPs' core broadband offerings themselves are information services even if ISPs don't offer e-mail and cloud storage. As we've previously written, Pai argues that broadband does not meet the statutory definition of telecommunications because consumers do not specify the IP addresses and caching servers they want to connect to when they go to a website. By law, telecommunications "means the transmission, between or among points specified by the user, of information of the user's choosing, without change in the form or content of the information as sent and received."

If you believe that selecting websites or online services to visit should be considered telecommunications under that definition, that's another topic you can discuss in comments to the FCC.

Lack of competition makes rules more important

Next, Sohn predicts that the FCC will argue that net neutrality rules "aren't necessary because if your ISP is discriminating, you can always choose another." While the FCC's own data demonstrates that this often isn't true in regard to high-speed home Internet service, personal examples can help illustrate the problem.

"You might address some or all these questions: what choices do you have at 25Mbps down and 3Mbps up (the FCC's definition of broadband)?" Sohn wrote. "Are they real choices or are all the ISPs charging the same prices for essentially the same service? What are the costs to you of switching? Would you suffer a financial penalty? Would you have to buy new equipment? Would you have to take a day or two off from work waiting for installation?"

Sohn also says commenters should write about what role they think the FCC should have in "overseeing the market for broadband Internet access." The common carrier classification allows the FCC to go beyond net neutrality rules in order to protect consumers from privacy invasions, fraudulent billing, and price gouging, she noted.

"If the FCC is left without authority over broadband ISPs, Comcast could double its prices overnight, and there wouldn't be anything the FCC or any other agency could do about it," Sohn wrote. "If you aren't OK with that, and think that broadband ISPs should be subject to oversight by an expert agency, tell the FCC why and what type of oversight you’d like to see."

How to file your comment

Even if you've already filed a comment, Sohn points out that you can file more comments addressing new issues. In fact, many companies and organizations file multiple comments on major proceedings such as this one.

You can file comments on Pai's plan to gut net neutrality rules at this link. Click "Express" to write a comment directly into the FCC form, or click "New Filing" to upload documents. Initial comments are due July 17, and reply comments (in which you can respond to other people's or organizations' comments) are due August 16.