The Center for Internet and Society issued a report last week (Filtering Out the Bots: What Americans Actually Told the FCC about Net Neutrality Repeal) claiming that many commenters on last year’s FCC proceeding on net neutrality showed a nuanced understanding of the regulatory issues. This seems like an odd claim so I checked it out.

My counter-theory is that most commenters were riled up by John Oliver and similar trolls and simply regurgitated what they had heard. While a small number of comments were thoughtful, most were emotional reactions unhelpful to the FCC.

To evaluate the two theories, I listed Oliver’s talking points and compared them to the comments filed in the 7th Congressional District of Colorado. This is a Democratic district in Denver’s western suburbs represented by Ed Perlmutter; it includes parts of Denver, Lakewood, Golden, Arvada, Westminster, and rural Jefferson County.

The comments I examined were judged legitimate by the CIS study as they weren’t believed to be form letter or bot-generated filings. They all came in through the Express Comment system, as directed by Oliver. In all, there were 2,635 unique comments in the sample.

Oliver’s Key Points

Oliver’s most recent net neutrality call-to-action was posted to YouTube on May 7, 2017. Key points:

• Explanation of Title I and Title II: 5:18
• Pai’s weed whacker comment about deregulation, with parody picture: 6:35
• Pai was once a Verizon lawyer: 8:36
• Net neutrality requires Title II classification: 9:30
• ISPs have committed many acts of “fuckery”: 10:20
• T-Mobile supports ISIS: 11:30
• Voluntary commitments in Terms of Service are meaningless: 12:07
• Investment went up under Title II: 12:37
• Congress can’t regulate ISPs: 14:59
• Go to gofccyourself.com to leave express comments in docket 17-108: 16:11
• “Leave a comment telling Ajit Pai that you specifically support strong net neutrality backed by Title II oversight of ISPs”: 16:19

Any comment limited to one or more of these talking points without relevant facts or reasoning is likely a reaction to Oliver, especially if it’s no more than two sentences long. Comments that offer reasoning or specific responses to the NPRM are more likely to represent nuanced understanding.

What the Comments Say

A small number of commenters openly admitted they were following Oliver’s directions: eight mentioned him by name and three said “gofccyourself”. Only one mentioned ISIS, but 24 called Chairman Pai a “Verizon lawyer.”

Of these, 18 used some variation of this sentence:

I’m sending this to the FCC’s open proceeding, but I worry that Chairman Pai, a former Verizon lawyer, has made his plans and will ignore me and millions of other Americans.So I’m also sending this to my members of Congress. Please publicly support the FCC’s existing net neutrality rules based on Title II, and denounce Chairman Pai’s   plans. Do whatever you can to dissuade him.Thank you!” [sic]

This looks like a form letter statement or a bot comment that wasn’t caught by the filter that was supposed to assure legitimacy.

There were 711 mentions of “Title II,” often multiple times in a single comment. There were also 434 mentions of “title 2” which may indicate the commenter had heard the term spoken but never seen it in print. One confused commenter urged the FCC to “Please maintain net neutrality and preserve it under title 1. And respectfully consider firing that verizon lawyer that now heads up the FCC.”

Another advised: “Don’t “loosen” the restrictions to title 1 or 2 or make any changes to net neutrality.” And they were also urged to “Please keep net neutrality title 2 at a minimum.” (Presumably Title III would be better?)

The Most Intriguing Comments

The comments I enjoyed most were variations on Oliver’s command to his viewers to leave comments “telling Ajit Pai that you specifically support strong net neutrality backed by Title II oversight of ISPs.” 38 comments took this literally, offering up these pearls:

“I specifically support strong net neutrally backed by Title 2 overusing of ISPs”

“I specifically support strong net neutrality backed by title II oversights of ISP’s”

“Ajit Pai, I specifically support strong net neutrality, that’s why we need Title II oversight of ISPs.”

“FCC,I specifically support strong Net Neutrality backed by Title II oversite of Internet Service Providers.”

“I specifically support strong Net Neutrality backed by title two over-cite of ISPs.”

“I specifically support strong net neutrality backed by tittle two oversight of isps.”

“We specifically support strong net neutrality. Title 2 oversight of ISP” [entire comment]

“I SPECIFICALLY SUPPORT STRONG NET NEUTRALITY BACKED BY TITLE II OVERSIGHT OF ISP’s.”

“I specifically support strong net neutrality backed by Title 2 (maybe written Title II) oversight of iSPs.”

“I, specifically support strong net-neutrality backed by Title II oversight of ISPs. Please reserve net-neutrality and Title II.”

“I specifically support strong net neutrality, that’s why tittle two over site of isp’s”

“I vigorously and specifically support strong net neutrality blacked by Title II oversight of ISPs.”

“After careful research, thought, and consideration, please be advised that I specifically support strong net neutrality, including classifying ISPs under Title II.”

“As the owner of a online business I specifically support strong net neutrality backed by Title II oversight of ISP’s.”

Most other comments simply paraphrased Oliver.

Some Comments Were Perfectly Sensible

The CIS analysis declares:

Reading through any of these reports make it clear that commenters clearly understand what net neutrality is. Many commenters also showed a nuanced understanding that classifying broadband providers under Title II allows the FCC to regulate those companies as common carrier, while a classification of broadband providers as “information services” under Title I of the Communications Act of 1996 would not allows the FCC to impose common carrier obligations.

While you can’t prove their claim by looking too closely for the obviously-Oliver driven outrage, there were some comments that showed familiarity with the NPRM. Three comments referred to specific questions; they were filed by Emilyn Winkelmeyer, Kendan Anderson, and “abigail”, all of Arvada.

Some more form letter comments leaked through with this boilerplate text: “Paragraph 82 asks for input on whether throttling should be regulated [various expressions of disapproval].” Sadly, the word “because” only appears 185 times in total across 2,635 comments and there is no variation on “correlates” or “correlation.” This is not a crowd that’s big on reasoning.

Conclusion

Out of 2,635 express comments filed in the Restoring Internet Freedom docket, only three addressed specific questions raised by the NPRM. Most comments were expressions of emotion, many of which were simply reactions to the John Oliver show.

While many Americans have strong feelings about the regulation of Internet Service Providers, few appear able to make a case for their desired outcome based on reasoning. The filter developed by Jeff Kao and used by CIS failed to flag a fairly large number of boilerplate comments.

While the number of legitimate comments filed with the FCC – probably closer to 500,000 than to the 800,000 claimed by CIS – indicates a high level of public engagement in the issue, it would be a mistake to conclude that net neutrality will be a significant campaign issue.

This is an issue of greater importance to comedians than to politicians.