Greetings all and thank you Dave Taht for that very kind intro...
First, I'll open with I'm a gosh-darn non-partisan, which means I swore an oath to uphold the Constitution first and serve the United States - not a specific party, tribe, or ideology. This often means, especially in today's era of 24/7 news and social media, non-partisans have to "top cover".
Second, I'll share that in what happened in 2017 (which itself was 10x what we saw in 2014) my biggest concern was and remains that a few actors attempted to flood the system with less-than-authentic comments.
In some respects this is not new. The whole "notice and comment" process is a legacy process that
goes back decades. And the FCC (and others) have had postcard floods of
comments, mimeographed letters of comments, faxed floods of comments,
and now this - which, when combined with generative AI, will be yet
another flood.
Which gets me to my biggest concern as a non-partisan in 2023-2024, namely how LLMs might misuse and abuse the commenting process further.
Both in 2014 and 2017, I asked FCC General Counsel if I could use
CAPTChA to try to reduce the volume of web scrapers or bots both filing
and pulling info from the Electronic Comment Filing System.
Both
times I was told *no* out of concerns that they might prevent someone
from filing. I asked if I could block obvious spam, defined as someone
filing a comment >100 times a minute, and was similarly told no
because one of those possible comments might be genuine and/or it could
be an ex party filing en masse for others.
For
2017 we had to spin up 30x the number of AWS cloud instances to handle
the load - and this was a flood of comments at 4am, 5am, and 6am ET at night which
normally shouldn’t see such volumes. When I said there was a combination
of actual humans wanting to leave comments and others who were
effectively denying service to others (especially because if anyone
wanted to do a batch upload of 100,000 comments or more they could
submit a CSV file or a comment with 100,000 signatories) - both parties
said no, that couldn’t be happening.
Until
2021 when the NY Attorney General proved that was exactly what was
happening with 18m of the 23m apparently from non-authentic origin with
~9m from one side of the political aisle (and six companies) and ~9m from
the other side of the political aisle (and one or more teenagers).
So with Net Neutrality back on the agenda - here’s a simple prediction,
even if the volume of comments is somehow controlled, 10,000+ pages of
comments produced by ChatGPT or a different LLM is both possible and
probably will be done. The question is if someone includes a legitimate
legal argument on page 6,517 - will FCC’s lawyers spot it and respond to
it as part of the NPRM?
Hope this helps and with highest regards,