Consider the following assertion:
“Our Constitution
establishes a system of dual sovereignty between the States and the federal
government, such that sovereignty rests concurrently with both the federal
government and the States. Specifically, the Tenth Amendment reserves all
powers not specifically delegated to the federal government by the Constitution
to the States or to the people. Thus,
States are not creations of the central government. They are separate
sovereigns. This distribution of sovereignty, otherwise known as federalism, is
the defining feature of the relationship between the federal and state
governments.
In taking this step
[preempting states from limiting the geographical reach of municipal broadband
networks] the FCC usurps fundamental aspects of state sovereignty. And it
disrupts the balance of power between the federal government and state
governments that lies at the core of our constitutional system of government.”
Now, compare it with
the following:
“The
broader problem is that California’s micromanagement poses a risk to the rest
of the country. After all, broadband is
an interstate service; Internet traffic doesn’t recognize state lines. It follows that only the federal government
can set regulatory policy in this area.
For if individual states like California regulate the Internet, this
will directly impact citizens in other states.
Among other reasons, this is why
efforts like California’s are illegal.”
Would you be surprised if I reported
that the same person wrote both declarations?
Any dismay at the apparent inconsistency if I reported that the author
is FCC Chairman Ajit Pai? Compare file:///C:/Users/rmf5/Downloads/FCC-15-25A5.pdf
with https://www.fcc.gov/document/chairman-pai-remarks-maine-policy-heritage-center.
Chairman Pai is a quite knowledgeable
and talented guy. However, I believe his
partisanship creates inconsistency on a fundamental principal—what he terms “Constitutional Law 101.”
Chairman Pai railed against the
Democratic majority at the FCC which sought to preempt state governments from imposing
geographical restrictions on municipal government broadband networks. For this matter, the Chairman invoked
federalism as sacrosanct: states are sovereign entities free to determine
whether and how subordinate governmental units can pursue broadband service
initiatives.
Chairman Pai had supporting case
precedent including a Supreme Court case validating the right of states to
prohibit any municipal telecommunications
service. See Nixon v. Missouri Mun.
League, 541 U.S. 125 (2004). The Sixth
Circuit Court of Appeals validated his legal interpretation ruling that the Telecommunications
Act of 1996 did not explicitly authorize the FCC to elevate the goal of ubiquitous
and affordable broadband over state sovereignty, even the sovereign election to
foreclose municipal efforts to rollout broadband where commercial ventures had
refused to serve. See Tennessee v. FCC, 832 F.3d 597 (6th Cir. 2016)available
at: http://www.opn.ca6.uscourts.gov/opinions.pdf/16a0189p-06.pdf.
With all this support for state’s
rights, how does Chairman Pai reverse course and invoke much maligned federal
preemption to thwart states like California from enacting network neutrality
laws?
Results-driven rationales now
support the view that anything and everything about broadband is interstate in
nature, and fair game for FCC preemption, except of course legislated service
limitations. I cannot square this view
with what Chairman Pai has previously stated.
California enacts a law, which I
consider quite flawed, but clearly representative of a sovereign state keen on
imposing consumer safeguards for the origination and termination of Internet
traffic within the state. Internet
Service Providers may import content from other states, but the delivery medium
surely lies within a single state.
Note that in the case of California
network neutrality legislation, a sovereign state has opted to impose
safeguards that the FCC considers unnecessary and potentially harmful. Can the FCC preempt states on grounds that
they cannot lawfully act when the Commission determines that regulatory
oversight is not needed?
How did humility and respect for
states’ rights evaporate?