NBC wants the federal government to believe that peer-to-peer file-swapping hurts... corn farmers? That's one of the claims made in NBC's controversial FCC filing, which also asks the government to require that Internet providers use mandatory content filters. "In the absence of movie piracy, video retailers would sell and rent more titles," says the filing. "Movie theaters would sell more tickets and popcorn. Corn growers would earn greater profits and buy more farm equipment." Everyone wins!

NBC's filing received a beatdown this week from advocacy groups like the EFF, Free Press, Public Knowledge, the US Public Interest Research Group, and the New America Foundation, which together submitted a "reply comment" of their own. Although the groups had submitted broader position papers over the course of the FCC's network neutrality comment period, this later reply has only a single objective: point out the flaws in NBC's dangerous line of argument.

The claim that content filtering can boost the revenue of corn farmers (which is already, thanks to ethanol, higher than the average American income) gets a footnote of its own in the new filing: "One could as easily argue," write the authors, "that the money consumers saved by not buying movie tickets they instead use to eat out in restaurants, thus helping farmers, restaurant owners, the automobile industry, and parking valets."

But the bigger issue here is that NBC wants the FCC to require ISPs to filter content. How this would work, exactly, is not explained, and as the public interest groups point out in their filing, "nearly any Internet protocol can be used to illegally transfer copyrighted materials—instant messaging, the Web, e-mail, and many other protocols are capable of being used for this purpose." The groups also argue that such filters (assuming that they work well, and this is a major assumption) would hinder fair use and would basically put the FCC in charge of setting Internet technology policy. After the agency was smacked down by the courts for exceeding its authority when it came to the broadcast flag, FCC officials are probably not in the mood to tackle such a controversial new policy.

One of the most important points made in the reply concerns NBC's charge that network neutrality (which this is all about) would prevent most "network management" tools from being used. Packet shaping, prioritization, deep packet inspection, bandwidth throttling—NBC argues that all of these tools would become illegal. This is a crucial question, since many of these management tools serve a useful purpose; does anyone not want VoIP traffic to be moved through network with less latency than, say, a P2P download?

The advocacy groups point out to the FCC that "non-discriminatory traffic shaping" would not violate their view of network neutrality. This means that protocols like VoIP could be prioritized, so long as that prioritization extended to all VoIP calls, from all users and all operators. Degrading or blocking applications like P2P would still be verboten, though.

Instead of seeking to get the government into the business of mandating ISP filtering technology, the advocacy groups argue that "companies need to adapt to technological progress, not devote their energies to stopping it." NBC has actually done a decent job of that, putting many of its shows on the web and offering hits like The Office on iTunes. But at least one part of the company is calling for heavy federal involvement in the Internet.

Sure, this is special interest politicking (for all NBC's talk of corn farmers, this is about its own revenues), but it looks like NBC is serious about this idea. Four weeks ago at a tech conference, GE exec Bob Wright took the stage to talk up Rick Cotton, the man who wrote the NBC filing, and to call again for better filtering tools (GE owns NBC). Expect the tough talk to continue from both sides in the run-up to the FCC's own decision on network neutrality.