The Federal Communications Commission's net neutrality repeal "is based on a flawed and factually inaccurate understanding of Internet technology," a group of inventors and technologists told members of Congress and the FCC in a letter today.

The letter's 21 signers include Internet Protocol co-inventor Vint Cerf; World Wide Web inventor Tim Berners-Lee; Apple co-founder Steve Wozniak, public-key cryptography inventors Whitfield Diffie and Martin Hellman; RSA public-key encryption algorithm co-inventor Ronald Rivest; Paul Vixie, who designed several widely used Domain Name System (DNS) protocol extensions and applications; and security expert and professor Susan Landau, who has fought against government attempts to make phone encryption less secure. The letter was also signed by former chief technologists at both the FCC and Federal Trade Commission, David Farber and Steven Bellovin, respectively.

FCC’s “flawed” understanding of Internet

The letter calls for a delay of this Thursday's FCC vote to deregulate broadband service and eliminate net neutrality rules. It says:

It is important to understand that the FCC's proposed Order is based on a flawed and factually inaccurate understanding of Internet technology. These flaws and inaccuracies were documented in detail in a 43-page-long joint comment signed by over 200 of the most prominent Internet pioneers and engineers and submitted to the FCC on July 17, 2017. Despite this comment, the FCC did not correct its misunderstandings, but instead premised the proposed Order on the very technical flaws the comment explained. The technically incorrect proposed Order dismantles 15 years of targeted oversight from both Republican and Democratic FCC chairs, who understood the threats that Internet access providers could pose to open markets on the Internet.

The FCC "ignored" this analysis from experts and failed to hold any public hearings to hear from citizens and experts before repealing the rules, the letter said.

The 43-page-long joint comment that the letter refers to argued that broadband access is a telecommunications service and thus must be regulated by the FCC under its common carriage rules. The FCC currently defines broadband as telecommunications, but FCC Chairman Ajit Pai's proposal would eliminate the FCC's authority to impose the current net neutrality rules by re-defining broadband as an information service.

Telecommunications, as defined by Congress in the Communications Act, transmits information of the user's choosing to and from endpoints specified by the user without making any changes to the user's information. Pai's proposal claims that broadband isn't telecommunications because, among other things, broadband users do not specify the IP addresses and caching servers they want to connect to when they select a website to view.

The joint comment in July stated:

Saying that Internet users do not specify the points to which information is sent online is like saying that telephone users do not specify the phone they want their call sent to when they dial a phone number... [T]his interpretation of what it means to transmit information between or among points specified by the user, i.e. that the user must explicitly tell the network what routing decisions to take, has no basis in reality. Taken to its logical conclusion, it would require the FCC to similarly decide that telephone services are also not telecommunications services—an obviously absurd conclusion.

The Electronic Frontier Foundation also summarized the argument in a post last week titled, "The FCC Still Doesn’t Know How the Internet Works."

Inventors call for vote delay

Today's letter also mentioned fraud in the FCC's public comments system, the FCC's refusal to provide documents requested under the Freedom of Information Act, and the FCC's refusal to provide evidence to a New York State Attorney General's investigation of comment fraud.

The letter asks members of Congress to step in and urge Pai to cancel this week's vote.

"The FCC's rushed and technically incorrect proposed Order to abolish net neutrality protections without any replacement is an imminent threat to the Internet we worked so hard to create," the letter says. "It should be stopped."

In general, Democratic lawmakers have called for the FCC to preserve net neutrality rules while Republican ones support the repeal.

We contacted Pai's office about the letter and will update this story if we get a response.