One in a Million: Coming Clean in the Net Neutrality Proceeding

Open Internet comments have passed the seven-figure mark, but one in particular sticks out.

Update: Word is that the total number of comments filed in the net neutrality proceeding leapt from around 650,000 the day before the original comment deadline, to more than 1,000,000 by the end of the extended comment period.

First, congrats to those of you who guessed right in your office’s over/under on the comment total – but don’t get too cocky. There are still a couple of months’ worth of reply comments yet to show up, so be sure to read the fine print on your internal office pool rules before you claim any prizes.

Second, with the new total, we have to revise the estimates we laid out in our earlier post. At that point, we estimated (based on then-available numbers) that, if 650,000 comments had been filed, one FCC staffmember doing nothing but net neutrality comment review for 52 40-hour weeks per year, and processing one comment every five minutes, would take more than 26 years to complete the job. With 1,000,000+ comments now in hand, let’s re-calculate. Under the conditions we are positing – and now also assuming that the hypothetical staffer would be willing to work beyond the usual retirement age – he or she would require 40 years to complete review of 1,000,000 comments.

And third, we want to highlight one particular submission which arrived in the FCC’s ECFS system on July 16. Filed by one Kurt Schaake (of Lawrence, Kansas), these comments consist, in toto, of a copy of the user instructions for a Whirlpool Dishwasher. True fact – you can find them for yourself by searching ECFS in Docket No. 14-28 (the Open Internet proceeding) or you can just click here to get there more quickly.

We’re frankly at a loss to understand what exactly Mr. Schaake is trying to say with his comments, but it could be a profound commentary about net neutrality. Is it intended to suggest that the FCC needs to come clean in some sense? Possibly the reference to “whirlpool” is meant to summon images straight from Poe’s A Descent into the Maelstrom, the implication being that the Commission is being sucked to the bottom of an unimaginably chaotic vortex from which the only escape is to abandon ship. (There’s a bright side there, though: the narrator in Poe’s story did survive.)

Maybe the message is that the FCC should not try to impose net neutrality regulations – after all, the “important safety instructions” ominously caution “do not tamper with controls”.

Elsewhere, the instructions inform that “[e]fficient dishwashers run longer to save water and energy, just as driving a car slower saves on gas.” Could that be a metaphor for Internet speeds? Apropos of speed, we are also told that “[h]eavier cycles and options affect cycle length” – isn’t that one of the primary complaints about heavy Internet traffic generators, like Netflix? But we are then told that “[y]ou can customize your cycles by pressing the options desired” – does that reflect a preference for a “fast line/slow lane” approach to net neutrality?

Obviously, more study is in order here. We suspect it will take more than five minutes to fully grasp the implications. We invite readers to let us know what you think Mr. Schaake’s comments mean.

[Blogmeister’s Note: Props to the folks at, which is where we learned of Mr. Schaake’s filing.]

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Comments (4) Read through and enter the discussion with the form at the end
Barry Skidelsky - July 21, 2014 10:37 AM

Given that you learned of Mr. Schaakes’s dishwasher related filing from (rather than by reviewing the nearly one million FCC comments filed -- although had that been a billable task paid at any hourly rate you would be the envy of every lawyer), perhaps the filer meant somehow to compare dirty and clean dishes to content, in which case he should have filed re indecency not net neutrality. Arguably, neither a dishwasher nor net neutrality is a necessity; and, while there are numerous private and public interest benefits associated with consumers eschewing dishwashers in favor of having fewer dishes and washing them by hand, the relevance of those benefits to net neutrality is not for me to say right now (I’ve got to get back to work). In parting, let me just add that your posting also brought to mind the dishwasher related observation (perhaps as politically correct as net neutraility) that: you might be a redneck if you think “loading the dishwasher” means getting your wife drink. Nuff said. - Barry Skidelsky, Esq., New York NY.

Steevo - July 26, 2014 9:32 PM

Perhaps Mr. Schaake is just testing to see if anyone is reading that million comments.

This proves that someone actually is though not an FCC employee.

Unless of course it can be shown that Mr. Schaake posted this himself to TechDirt, thus weaseling himself out. If that is the case I have no idea what he is trying to prove.

fgoodwin - July 30, 2014 9:32 AM

Mr. Schaake is exercising his First Amendment right to say whatever he damn well pleases about net neutrality, relevance be damned! I hope he is happy that the Whirlpool manual is now part of the FCCC's official record in the Net Neutrality proceeding, for all the good it will do. Ain't free speech grand!

fgoodwin - August 7, 2014 8:49 AM

Why isn't this a "frivolous" comment, per 47 CFR 8.13(d) and subject to "appropriate sanctions"?

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