There are a lot of good things for Comcast in the Federal Communications Commission’s network neutrality proposal, and Comcast is smart enough to recognize it.

Today, Comcast Executive VP David Cohen announced that “we support the FCC putting in place legally enforceable rules to ensure that there is a free and open Internet, including transparency, no blocking, and anti-discrimination rules.”

Comcast submitted a 71-page filing to the FCC in which Senior VP of Regulatory Affairs Kathryn Zachem laid out the reasons for the company’s support. The rules are so good, Comcast said, that it might be wise to apply them to cellular carriers as well as fixed Internet providers.

Comcast also supports what FCC Chairman Tom Wheeler's proposal doesn’t do. For example, the proposal would not reclassify broadband Internet as a common carrier service that would be subject to utility-style regulation, and the proposal would not regulate interconnection deals, such as the one in which Comcast charges Netflix for a direct connection to its network.

Comcast's support of the FCC also seems to be part of its plan to win approval of its acquisition of Time Warner Cable (TWC).

The FCC's previous net neutrality rules were largely thrown out this year by a federal appeals court after a lawsuit by Verizon. Comcast today is the only company that has to follow the old rules, and it must do so until 2018 due to a condition of its purchase of NBCUniversal. Comcast has repeatedly touted this commitment as part of its attempt to acquire TWC, and today the company repeated its pledge to extend net neutrality protections to TWC territory. Comcast was caught delaying BitTorrent traffic before the FCC's first neutrality rules went into place.

Comcast says it has no plans to offer fast lanes

The FCC’s new proposal would require ISPs to provide a minimum level of service, but controversially, it also allows ISPs to charge Web services for “fast lanes” in which their traffic would be accelerated beyond the speeds given to services that don’t pay for special access. Fast lanes are different from interconnection deals like the Netflix/Comcast one. Netflix pays for an uncongested on-ramp to the Comcast network, but it doesn’t get any priority after its traffic enters the Comcast network and starts traveling to customers' homes.

Comcast has claimed previously that it’s allowed to offer fast lanes despite the NBCUniversal condition but chooses not to. Today, Comcast told the FCC that fast lanes should be allowed but limited.

“For its part, Comcast has not entered into a single 'paid prioritization' arrangement, has no plans to do so in the future, and does not even know what such an arrangement would entail as a practical matter,” Comcast wrote. “Nonetheless, Comcast supports the Commission in its effort to apply an enforceable legal standard for determining which limited arrangements should be permitted.”

Comcast “would not be opposed” to a standard in which paid prioritization arrangements are considered commercially unreasonable unless proven otherwise. Comcast wrote:

A broadband provider seeking to justify any “paid prioritization” arrangement could be required to bear the burden of showing that the arrangement is commercially reasonable and fair to consumers and edge providers. Comcast believes that few arrangements would be deemed to overcome the presumption. However, the Commission should not establish a policy that would preclude all experimentation in this area. Arrangements could emerge between broadband providers and edge providers that could have widely varying implications for competition and consumer welfare based on the terms of an individual arrangement, the parties involved, and the markets affected.

Despite the allowance for fast lanes, the FCC proposal would prohibit ISPs from blocking services. Comcast said it supports a no-blocking rule.

In fact, Comcast believes that the FCC should consider extending net neutrality rules to cover cellular service. The commission’s 2010 rules largely exempted wireless, and the new proposal tentatively concludes that the FCC should continue that approach, meaning that Comcast has to follow more strict rules than cellular companies.

“Unlike the broad no-blocking and nondiscrimination rules applicable to fixed services, the [2010] no-blocking rule for mobile services applied only to websites and to applications that ‘compete with the provider’s voice or video telephony services,’ and there was no non-discrimination rule at all for mobile services,” Comcast wrote. “While such regulatory distinctions might have been defensible in 2010, the NPRM’s [Notice of Proposed Rulemaking's] recognition of the ‘significant changes since 2010 in the mobile marketplace’—including ‘how mobile providers manage their networks, the increased use of Wi-Fi, and the increased use of mobile devices and applications‘—supports at least a refreshed examination of that approach. There is no question that wireless is increasingly becoming a closer substitute for wireline broadband for many uses and for many Americans.”

However the FCC decides to treat cellular, it should apply the same approach to public Wi-Fi networks, Comcast said.

“A given wireless user may be accessing the Internet over a licensed mobile broadband network one minute and over an unlicensed Wi-Fi network the next with the same device,” Comcast wrote. “It would be unreasonable—and likely arbitrary and capricious—to subject such traffic to one set of rules while it is delivered over a licensed mobile broadband network and a different set of rules whenever it is offloaded or shifted to a Wi-Fi network.”

“Light-touch regulation” is what makes Comcast so innovative

Comcast also explained why the FCC should continue its approach of treating broadband as an “information service” rather than a telecommunications service that would be subject to stricter common carrier rules.

The FCC’s approach “has enabled light-touch regulation that has fostered dynamic innovation and unprecedented investment in broadband networks such as Comcast’s and allowed the broader Internet ecosystem to thrive,” Comcast wrote. “Seeking to reverse the classification now would be a profound mistake.”

The FCC also shouldn’t get involved in the interconnection market, Comcast said. The FCC is examining the paid peering deals Netflix signed with Comcast and Verizon, but it hasn’t proposed any rules that would stop or limit such agreements.

“Traffic-exchange arrangements have nothing to do with the ability of end users to access particular content or to use particular applications or services, and nothing to do with the priority with which content might be delivered to end users over a broadband Internet access service,” Comcast argued. “For these reasons, Chairman Wheeler correctly acknowledged in his statement accompanying the NPRM that traffic exchange ‘is a different matter that is better addressed separately’ from this proceeding, and explained to industry stakeholders in February that traffic exchange ‘is not the same issue’ as net neutrality.”

The FCC today said it has received 780,000 comments on its net neutrality plans. Many people and organizations want stronger rules. Netflix, for example, argues that paid interconnection deals like the ones it struck with Comcast and Verizon should be banned. Many people, including New York Attorney General Eric T. Schneiderman and Illinois Attorney General Lisa Madigan, have argued that broadband should be reclassified as a common carrier service, contrary to Comcast's wishes.