OTI Legislative and Regulatory Filings 2023
Legislative and Regulatory Filings
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Jan. 27, 2023
Note: This page will be regularly updated as we file comments, sign on to coalition letters, and complete other legislative and/or regulatory filings.
December
- OTI Urges FCC To Update Definition of Broadband Speeds, Recognize Necessity of Fixed Broadband, and Consider Affordability in Determining Broadband Availability
- OTI filed comments urging the Federal Communications Commission (FCC) to update its definition of broadband speeds, to recognize that mobile broadband is not a comparable substitute to fixed at-home broadband service, and to consider affordability in determining broadband availability as part of its Section 706 review.
- OTI Welcomes OMB Guidance on AI, Suggests Improvements
- OTI filed comments in response to the Office of Management and Budget’s (OMB) Draft Memorandum On Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence, both supporting important aspects of the Memorandum and noting areas that would benefit from clarification, amendment, or further development.
- OTI Joins Public Knowledge and Others in Opposing an Extension of the Title II NPRM Deadline
- OTI joined Public Knowledge and 11 other groups in filing to oppose a motion to delay the implementation of the Federal Communications Commission’s long-anticipated action to restore broadband consumer protections (by recognizing that broadband internet access service is a telecommunications service) and to reinstate Open Internet rules, calling it an “unwarranted gambit.”
- OTI and Other Affordable Broadband Groups Urge FCC To “Maintain Maximum Flexibility” Regarding Future of Universal Service Fund Programs
- OTI joined more than a dozen other affordable broadband groups in calling on the Federal Communications Commission to “refrain from forbearing from the exercise of Section 254(d) as this could prematurely hamper the ability of the Commission efforts to timely modernize and fund the Universal Services programs.”
- OTI and 60+ Other Civil Society Representatives Urge Indian Government To Withdraw Telecommunications Bill, 2023
- OTI joined more than 60 other civil society representatives in writing to the Indian government, urging it to immediately withdraw the Telecommunications Bill that had been rushed through both houses of parliament, as the Bill, in its current form, “poses a grave threat to fundamental rights, democracy, and the internet as we know it.”
October
- OTI Joins 86 Other Groups in Calling on Congress To Consider Current Harms of AI
- OTI and a broad coalition of 86 other civil society groups sent a letter to U.S. Senators and Representatives, urging them to “consider the varied ways in which AI is already impacting our economy and society, particularly historically marginalized communities” and “work closely with civil society to pursue legislation that achieves meaningful, rights-respecting AI accountability.”
- Global Encryption Coalition Urges Governments and Private Sector to Defend Encryption
- OTI joined supporters of the Global Encryption Coalition in calling on governments and the private sector “to reject efforts to undermine encryption and instead pursue policies that enhance, strengthen, and promote use of strong encryption to protect people everywhere.”
September
- OTI and 60 Others Sound Alarm on STOP CSAM Act’s Threats to Free Expression and Privacy
- OTI joined 60 other groups in calling out the Strengthening Transparency and Obligations to Protect Children Suffering from Abuse and Mistreatment Act (STOP CSAM Act), which “would lead apps and websites to surveil every single word, image, and video its users post, censor First Amendment protected speech, and stop offering services that are critical for enabling secure, private conversations.”
- OTI Calls Out the STOP CSAM Act, EARN IT Act, and Cooper Davis Act’s Threats to Civil Rights
- OTI and a dozen other groups came together to sound the alarm on the STOP CSAM Act, EARN IT Act, and Cooper Davis Act, which “threaten the civil rights of Black, Brown, and LGBTQ+ people, including by undermining encryption technologies and contributing to over-policing and surveillance.”
- Coalition Statement on PCLOB 702 Report
- OTI, along with 19 other groups, released a statement on the Privacy and Civil Liberties Oversight Board’s recently published report on Section 702, emphasizing how important it is for PCLOB to go a step further by addressing the government’s use of data brokers to circumvent legal protections for Americans’ privacy and the use of overseas surveillance to collect Americans’ information without statutory authority or judicial oversight.
July
- OTI and 16 Other Groups Oppose Overbroad Counter-Drone Bill
- OTI joined a coalition of 16 other human rights, civil liberties, and civil rights organizations in coming out in opposition to S.1631 (The Safeguarding the Homeland from the Threats Posed by Unmanned Aircraft Systems Act), a counter-drone bill that “provides overbroad authority for takedowns, inadequately protects First Amendment and press activities, does not include due process protections for improper counter-drone activities, and lacks basic transparency rules to facilitate responsible use.”
June
- OTI and 40 Other Civil Rights Groups Call on the FTC To Develop Specific, Concrete Civil Rights Protections in Ongoing ANPR
- OTI joined 40 other civil rights groups in urging the Federal Trade Commission to institute “a specific rule prohibiting discrimination as an unfair practice under the FTC Act” and issue “a specific rule requiring reasonable and appropriate measures to detect and address algorithmic discrimination in sensitive domains” in its ongoing Commercial Surveillance and Data Security Rulemaking (ANPR).
- OTI and 60+ Other Organizations Urge OMB, DPC, and OSTP To Take Next Steps in Addressing AI
- OTI joined a coalition of more than 60 civil rights, technology, policy, and research organizations in calling on the White House’s Office of Management and Budget, Domestic Policy Council, and Office of Science and Technology Policy to “take the necessary next steps to advance a whole-of-government approach to addressing the impact of artificial intelligence (AI) on people’s rights and opportunities.”
- OTI and 230+ Others Urge Robust ACP Funding
- OTI joined more than 230 civil society organizations, municipal governments, and other interest groups in urging members of Congress to push for robust additional funding for the Affordable Connectivity Program (ACP), noting that a failure to extend the ACP with new funding “could result in the biggest loss of internet connectivity ever.”
May
- OTI Opposes EARN IT Act on Account of Potential Data Privacy Violations, Censorship, and More
- OTI joined 132 other groups in expressing serious concerns about the Eliminating Abusive and Rampant Neglect of Interactive Technologies Act of 2023 (EARN IT Act), which would “make it harder for law enforcement to protect children,” result in online censorship that would “disproportionately impact marginalized communities,” and “jeopardize access to encrypted services, undermining a critical foundation of security, confidentiality, and safety on the internet.”
- OTI Signs Coalition Letter in Support of the Affordable Connectivity Program
- OTI joined a coalition of 164 civil society organizations, municipal governments, and other interested groups in urging Congressional appropriators to grant robust additional funding for the Affordable Connectivity Program (ACP).
April
- OTI Joins Call To Strengthen FTC With Increased Funding
- OTI joined a coalition of 15 other privacy, child, and consumer advocates in asking appropriators to support the Federal Trade Commission’s budget request of $590 million for Fiscal Year 2024, so that the FTC can more effectively protect American consumers and promote competitive markets across the economy.
March
- OTI Recommends Comprehensive Privacy Legislation Emphasizing Data Minimization and User Rights Protections in NTIA Comments
- OTI filed comments to the National Telecommunications and Information Administration, exploring the potential harms of commercial data collection and use of automated decision-making, as well as on potential action that can be taken by stakeholders, including industry and government.
- OTI Signs Joint Letter Urging Nuance on Section 230 Debate, Highlighting How It Supports Communities and Enables User Expression Online
- OTI joined a coalition of 37 diverse organizations in signing a joint letter to members of the Senate Judiciary Committee, acknowledging the complex and nuanced issues surrounding Section 230 and highlighting its support of communities’ user expression online.
- OTI and 60+ Other Groups Call on President Biden To Immediately Put Forth a Strong, New FCC Nominee
- OTI joined a broad coalition of more than 60 groups in urging President Biden to immediately put forth a strong, new Federal Communications Commission nominee—specifically, one who has a history of advocacy for the public interest and is free of industry conflicts of interest; demonstrates a clear commitment to championing the rights of low-income families and communities of color; and supports Title II oversight and laws that ensure the FCC the authority to prevent unjust discrimination and promote affordable access.
- OTI, With Other Free Speech Organizations, Sends Letter to Congress Opposing Proposed National TikTok Ban
- OTI joined 15 other groups in taking a stand against current legislative and administrative proposals to ban TikTok in the U.S., which would “risk violating First Amendment rights & setting a dangerous global precedent for the restriction of speech.”
February
- OTI Urges FTC To Curtail “Junk Fees” for Internet Service
- OTI filed comments to the Federal Trade Commission noting the prevalence of unnecessary “junk fees” in both wireless and wired internet connections, urging the agency to crack down on fees that provide no value to consumers, make internet prices opaque, impede comparison shopping, and harm competition.
- OTI Joins Civil Rights Group Letter in Support of Sohn Nomination
- OTI joined more than 40 other civil rights groups in urging the leaders of the U.S. Senate Committee on Commerce, Science, and Transportation to ensure that Ms. Gigi Sohn’s Federal Communications Commission nomination is considered by the committee as soon as possible and reported favorably to the full Senate.
- OTI Urges FCC To Strengthen Broadband Nutrition Label
- OTI filed comments to the Federal Communications Commission, urging the agency to strengthen the new broadband nutrition label by ensuring a multitude of language translations and incorporating additional information on price, performance, network management, and privacy.
January
- OTI and 38 Other Advocacy Groups Urge White House To Ensure That Any Appointees Replacing Tim Wu at the NEC Have a Similarly Anti-Monopolistic Track Record
- OTI joined a broad coalition of advocacy groups in urging the White House to ensure that any individuals appointed to the National Economic Council to work on the competition issues that Tim Wu worked on as Special Assistant to the President for Technology and Competition Policy have similar track records and a history of demonstrating firm commitments to anti-monpoly policy.