Tag Archives: net neutrality

Government Petitioners’ Brief Points Out Verizon Throttling of Fire Department Battling Largest Fire in California History

On August 20, 2017, petitioners challenging the FCC’s abandonment of net neutrality protections in Mozilla v. FCC filed their initial briefs. Coverage of Mozilla’s joint brief with other non-government petitioners (including companies and public interest groups) is available here and here. This blog post focuses on the brief filed by government petitioners, which include 22 states (New York, California, Connecticut, Delaware, Hawaii, Illinois, Iowa, Kentucky, Maine, Maryland, Massachusetts, Minnesota, Mississippi, New Jersey, New Mexico, North Carolina, Oregon, Pennsylvania, Rhode Island, Vermont, Virginia, and Washington), the District of Columbia, the County of Santa Clara, Santa Clara County Central Fire Protection District, and the California Public Utilities Commission. These states represent over 165 million people, approximately half of the United States population.

The brief of the government petitioners make two primary arguments: 1) that the 2017 Order is arbitrary and capricious and failed to take into account harm to consumers, including public safety issues; and 2) the FCC did not have valid authority to preempt state and local laws from enacting their own net neutrality protections.

The highlight of this government petitioners’ brief focuses on clear and real examples of the harms that absence of net neutrality protections will have on safety, health and the public interest. While the FCC’s 2017 reversal of net neutrality protections relies on voluntary commitments, Internet companies have demonstrated that they will prioritize their own interests over the public’s:

BIAS [Broadband Internet Access Service] providers have shown every indication that they will prioritize economic interests, even in situations that implicate public safety. For example, a BIAS provider recently throttled the connection of a County Fire emergency response vehicle involved in the response to the largest wildfire in California history and did not cease throttling even when informed that this practice threatened public safety (emphasis added).

In this case, while the County was fighting the Mendocino Complex Fire—the largest fire in California’s state history—it experienced throttling by its ISP, Verizon. The addendum to the government petitioners’ brief includes a declaration by Santa Clara County Fire Chief, Anthony Bowden, who notes that the fire department relies on “Internet-based systems to provide crucial and time-sensitive public safety services. The Internet has become an essential tool in providing fire and emergency response, particularly for events like large fires, which require the rapid deployment and organization of thousands of personnel and hundreds of fire engines, aircraft, and bulldozers. During these events, resources are marshaled from across the state and country—in some cases even from other countries” and management of these resources depends on the Internet.

As Bowden explains, the unit facilitating resources “typically exchanges 5-10 gigabytes of data per day via the Internet using a mobile router and wireless connection. Near real-time information exchange is vital to proper function . . . Even small delays in response translate into devastating effects, including loss of property, and, in some cases, loss of life.” As a result, high-speed Internet is critical in addressing these fires.

Despite the fact that Santa Clara County Fire believed it had purchased an “unlimited” data plan, Verizon throttled the County’s usage “and data rates had been reduced to 1/200, or less, than the previous speeds.” When employees of Santa Clara County Fire e-mailed with Verizon, requesting the throttling be lifted for public safety purposes:

Verizon representatives confirmed the throttling, but rather than restoring us to an essential data transfer speed, they indicated that County Fire would have to switch to a new data plan at more than twice the cost, and they would only remove throttling after we contacted the Department that handles billing and switched to the new data plan.

Indeed, in the e-mail exchange attached as an exhibit in the addendum, a reported “side by side comparison a crew members personal phone using Verizon was seeing speeds of 20MBps/7Mbps. The department Verizon device is experiencing speeds of 0.2Mbps/0.6MBps, meaning it has no meaningful functionality.”

In another e-mail exchange questioning why Verizon was throttling the Santa Clara County Fire when the County believed it had purchased unlimited data, a Verizon manager replied, “Verizon has always reserved the right to limit data throughput on unlimited plans. All unlimited data plans offered by Verizon have some sort of data throttling built-in.”

While Verizon’s response to the Santa Clara County Fire Department in the midst of fighting the largest fire in California history as an extreme example of an ISP acting in self-interest, there are other examples of concerns for other state and local government seeking to serve the health and safety needs of its residents. For example, the government petitioners’ brief points to California’s updates to manage its energy grid to balance load, manage congestion and satisfy reliability standards.

Another example cited by the County of Santa Clara is its “web-based emergency operations center to facilitate coordination internally with other agencies and with first responders in case of emergency.” It uses a web-based public alert system to notify the public about emergencies such as evacuation orders or disease outbreaks and “Significant delays from blocking, throttling, or deprioritization could impede effective notification and jeopardize safety in public-health emergencies.” The County’s hospital also uses web-based systems that are latency-sensitive, including development of expanded telemedicine capabilities which will allow doctors to “perform triage and improve outcomes in time-sensitive situations (such as strokes or vehicular accidents) where immediate diagnosis can mean the difference between life and death.” In developing these improved systems for public health and safety, the County of Santa Clara notes that it invested substantial resources, including over a million dollars in its medical records system, and did so in reliance on the FCC’s protection of an open Internet.

Ultimately, the government petitioners’ brief highlights the ways that state and local government rely on an open Internet to serve the public, health and safety needs of its residents. As the brief notes, the FCC erred in assuming

that providers’ voluntary commitments coupled with existing consumer protection laws provide sufficient protection. The Commission offered no meaningful defense of its decision to uncritically accept industry promises that are untethered to any enforcement mechanism. Nothing in the order would stop a BIAS provider from abandoning its voluntary commitments, revising its Transparency Rule disclosures, and beginning to block, throttle, or engage in paid prioritization, subject only to the Transparency Rule’s limited disclosure requirements—leading to the very harms to consumer interests and public safety that the Commission’s long-standing commitment to protecting the open Internet was intended to prevent.

Mozilla, Internet Companies, Public Interest Groups and Other Petitioners File Brief in Net Neutrality Case

The litigation around the FCC’s decision in 2017 to abandon net neutrality protections is currently before the D.C. Circuit in the case captioned as, Mozilla v. FCC. Briefs by petitioners challenging the FCC’s 2017 Order were filed on Monday, August 20. The first brief (“non-government petitioners”) was filed jointly by Mozilla, Vimeo, Public Knowledge, Open Technology Institute, National Hispanic Media Coalition, NTCH, Benton Foundation, Free Press, Coalition for Internet Openness, Etsy, the AD Hoc Telecom Users Committee, Center for Democracy and Technology and Encompass and a summary of its arguments is provided below. The second brief, which will be covered in separate blog post, was filed by government petitioners, consisting of 22 states, the District of Columbia, County of Santa Clara, Santa Clara County Central Fire Protection District and the California Public Utilities Commission.

The non-government petitioners include a wide range of affected stakeholders: Internet companies, broadband providers, Internet consumers and public interest groups.

Mozilla’s brief points out that the FCC’s 2015 Open Internet Order was the result of a lengthy notice of proposed rulemaking and careful consideration, “Yet in the aftermath of the 2016 presidential election, the FCC did an abrupt about-face, comprehensively embracing the BIAS [Broadband Internet Access Service] providers’ objections this Court rejected in USTA and Verizon, revoking the telecommunications service designation of fixed and mobile BIAS, repealing all the rules governing BIAS provider conduct, and disavowing every source of authority for such rules.” Indeed, as numerous critics have noted, the 2017 decision by the FCC reversing its early Open Internet Order seemed to be a predetermined outcome.

Mozilla’s brief makes several arguments: 1) the FCC’s Order mischaracterizes the way the Internet works; 2) the FCC impermissibly renounced its enforcement authority; and 3) the FCC’s repeal of the 2015 Open Internet Order was arbitrary and capricious, ignoring the reasoned decision-making required by an agency.

Pointedly, Mozilla’s brief notes: “In 2016, this Court upheld the rules in their entirety. In 2017, a new FCC undid them, again in their entirety, on a record that had changed little, if at all.” Additionally, “One after another, the FCC reversed virtually all of the 2015 Order’s hundred-plus factual findings, proclaiming wrong what had been found to be right in 2015 and upheld as right in 2016. The abrupt about-face was not adequately reasoned.”

In arguing the arbitrary and capricious nature of the FCC’s reversal of the 2015 Open Internet Order, Mozilla’s brief points out that the FCC “erroneously excluded consumer complaints”* resulting in “skewing the record in favor of its preferred outcome and subverting the rulemaking process.” Such behavior contravenes the Administrative Procedures Act (APA) which requires agencies to examine relevant data and provide reasoned explanations; “an agency cannot close its eyes to evidence in its possession on which it chooses not to rely.”

The FCC’s complete abandonment of net neutrality protections ignored not only the lengthy and detailed record in past proceedings, but also the comments submitted in its 2017 notice of proposed rulemaking. Various amici for the petitioners, whose briefs will be due on Monday, August 27, will also point to the arbitrary and capricious decision-making by the FCC.

*A representative (but not comprehensive) list of companies, organizations and governments is listed on the first several pages.  Several library organizations (including ARL, ALA, and AALL) along with city governments, state governments, public interest groups and companies, are included.

ARL Urges US House of Representatives to Restore Net Neutrality

*Cross-posted from ARL News*

The Association of Research Libraries (ARL) is profoundly disappointed with the US Federal Communications Commission’s (FCC) repeal of the Open Internet Order, which takes effect today, June 11, 2018. ARL is calling on the House of Representatives to reverse the FCC’s decision and restore net neutrality, a bedrock of equitable access to information.

As of today, internet service providers (ISPs) can legally prioritize some voices—those willing and able to pay a premium—over others, such as nonprofit organizations or people holding minority viewpoints. Instead of ensuring that users can access the content of their choosing on an equitable basis, the FCC is now relying solely on market forces to regulate the flow of internet traffic. This will almost certainly lead to many blocking/paid-prioritization arrangements between ISPs and commercial entities.

One possible avenue to retain net neutrality is through the Congressional Review Act (CRA). Under CRA, Congress can overturn an agency’s decision with a simple majority vote in both houses within 60 legislative days of publication of the agency’s decision in the Federal Register. If both houses vote to overturn the decision, it will then require the signature of the President. The CRA resolution to reverse the FCC’s repeal of the Open Internet Order passed the Senate 52-47 on May 16. The House of Representatives can save net neutrality by taking up the issue and voting in favor of the similar CRA resolution introduced by Representative Doyle (D-PA). The House must act by mid-July if it is to pass a CRA resolution restoring the Open Internet Order.

“Net neutrality was essentially a nondiscrimination rule enabling the free and open exchange of ideas, thereby helping libraries fulfill their mission of advancing education, innovation, knowledge creation, and economic growth,” said Mary Ann Mavrinac, president of ARL and vice provost and the Andrew H. and Janet Dayton Neilly Dean of the University of Rochester Libraries. “We call on the House of Representatives to pass the CRA resolution restoring the open internet and we urge President Trump to sign it.”

Challenges to the FCC’s repeal of the Open Internet Order are also currently pending before the US Court of Appeals for the DC Circuit. ARL is working with other library and higher education associations to advocate for the restoration of strong net neutrality protections through submission of an amicus brief highlighting the importance of these rules for access to information, research, education, and freedom of speech.

Take action on this issue by emailing, calling, or tweeting to your Representatives and encouraging them to restore an open internet by voting for the CRA resolution. Battle for the Net provides an easy way to email, call, and tweet to your lawmakers.

In Vote to Restore Net Neutrality Rules, Several Senators Note Importance of Open Internet for Research, Education and Equity

Today, May 16, 2018, the US Senate voted 52-47 to reverse the FCC’s decision that would eviscerate protections for net neutrality.  The Senate used a procedure known as the Congressional Review Act (CRA), allowing Congress to reverse an agency’s decision with a simple majority vote within 60 legislative days of publication of an agency’s decision in the Federal Register. ARL and other net neutrality advocates are celebrating this vote, which as of just a week ago was not assured of passage.

All 49 members of the Democratic caucus voted in favor of the discharge petition and resolution, originally introduced by Senator Markey (D-MA), and were joined by Republican Senators Collins of Maine, Kennedy of Louisiana and Murkowski of Alaska.

The debate on the floor (video available here) included several statements acknowledging the importance of net neutrality to a wide range of constituents, including the research, library and education communities.  For example, Senator Nelson (D-FL) pointed out that education is built on an open Internet:

. . . and that’s why educators and librarians throughout the country have rallied in favor of net neutrality, knowing that an Internet is no longer free and open is a lost education opportunity for our children. Florida’s colleges, universities, and technical schools rely on the free and open Internet for their vital educational and research missions. Unfettered access to the Internet is essential to research, research into issues as critical to the state and nation as medical research, climate change, sea level rise, whatever the research is.

Nelson went on to note the importance of an open Internet as an equitable issue:

Citizens throughout my home state rely on the internet for civic and social engagement. The internet is today’s social forum. It’s a tool that we use to stay engaged in the lives of family, friends, and peers. The internet can also be an equalizing force, and as such has been a place where communities of color have been able to tell their own stories in a way that they have never been able to tell before, and it has given minority communities the power to organize, to share, and to support each other’s causes every.

Senator Murray (D-WA) spoke as a former educator, pointing out:

Schools have worked very hard to improve access to high-speed connectivity for all students because they know from early education through higher education and through workforce training, students need high-speed internet in order to learn and get the skills that they need.

Senator Markey cited a wide range of stakeholders supporting net neutrality as a right:

This vote is a test of the United States Senate and the American people are watching very closely. This vote is about small businesses, librarians, school teachers, innovators, social advocates, YouTubers, college students and millions of other Americans who have spoken with one voice to say, “Access to the Internet is our right and we will not sit idly by while this Administration stomps on that right.” This vote is our moment to show our constituents that the United States Senate can break through the partisanship and break past the powerful outside influences to do the right thing. The right thing for our economy, the right thing for our democracy, the right thing for our consumers, and the right thing for our future. This is common sense to Americans around the country, with the only exception being telecom lobbyists and lawyers inside the beltway. How do I know? Because 86% of all Americans in polling agree that net neutrality should stay on the books as the law of the United States.

Minority Leader Schumer (D-NY) urged his fellow Senators to vote in favor of the CRA resolution and treat the Internet as a public good, ensuring that discrimination does not occur.  He noted that without net neutrality,

. . . the Internet wouldn’t operate on a level playing field. Big corporations and folks who could pay would enjoy the benefits of fast internet and speedy delivery to their customers, while start-ups, small businesses, public schools, average folks, communities of color, rural Americans could well be disadvantaged. Net neutrality protected everyone and prevented large ISPs from discriminating against any customers. That era, the era of a free and open Internet, unfortunately will soon come to an end . . .

It may not be a cataclysm on day one, but sure as rain, if Internet service providers are given the ability to start charging more for preferred service, they’ll find a way to do it . . .Let’s treat the Internet like the public good that it is. We don’t let water companies or phone companies discriminate against customers. We don’t restrict access to interstate highways saying you can ride on the highway, you can’t. We shouldn’t do that with the Internet either.

This Senate vote in favor of restoring net neutrality protections will put pressure on the House of Representatives, which will need all members of the Democratic caucus plus 22 Republicans to discharge the petition and force a vote. While action using CRA in the House of Representatives faces an uphill battle, public polling reveals that more than 80% of Americans support net neutrality and this issue is one that will likely be a prominent in the upcoming elections. Battle for the Net provides an easy tool for individuals to contact lawmakers and urge them to vote to reverse the FCC’s decision.

For a deeper dive into impacts of the loss of net neutrality for research and higher education as well as legal and policy issues, see the latest issue of Research Library Issues. For additional statements and materials related to today’s vote in the Senate, visit this post on InfoDOCKET.

#RedAlert: One More Vote Needed in the Senate to Save #NetNeutrality

In mid-December 2017, the Federal Communications Commission (FCC) voted to reverse the strong net neutrality protections that had been put into place by the 2015 Open Internet Order. Since that time, advocates for net neutrality—an important concept based on the principle that internet service providers (ISPs) should permit access to all lawful content, without favoring some content over others—have continued to fight to ensure that the open character of the internet remains.

In addition to challenging the FCC’s actions through litigation, one possible avenue to retain net neutrality protections is through a process in Congress known as the Congressional Review Act (CRA). Under CRA, Congress can overturn an agency’s decision through a simple majority vote in both houses within 60 legislative days of publication of an agency’s decision in the Federal Register. It would then require the signature of the President.

Soon after a CRA resolution was introduced by Senator Markey (D-MA) to reverse the FCC’s decision, the Senate version garnered enough co-sponsors to force a vote under Senate rules and Minority Leader Schumer (D-NY) has vowed to hold a vote. To date, 50 senators have co-sponsored the resolution, including all 49 members of the Democratic caucus and Senator Collins (R-ME). Only one more vote is needed for CRA to pass the Senate and with today’s discharge petition, a vote will take place in the Senate by June 12.

An open internet is fundamental to ensuring that access to information remains equitable and that some content is not privileged over others. Net neutrality is based on critical non-discrimination principles, promoting freedom of speech and the Senate could take a welcome step in confirming the importance of an open internet. For a deeper dive into impacts of the loss of net neutrality for research and higher education as well as legal and policy issues, see the latest issue of Research Library Issues.

To help secure one more vote—the critical vote for passage of CRA in the Senate—contact your Senator. Battle for the Net provides an easy way to e-mail, call and tweet your lawmaker.

ARL Urges FCC To Maintain Strong Net Neutrality Provisions, Submits Two Sets of Reply Comments

Last week, ARL submitted two sets of reply comments to the Federal Communications Commission (FCC) urging the Commission to maintain strong protections for net neutrality.  ARL joined with eight other higher education associations to file reply comments noting that an open Internet is fundamental to the service missions of institutions of higher education and libraries, that Title II provides a strong legal basis to protect and preserve an open Internet, while also pointing to possible protections the FCC could enact under Section 706.  Additionally, ARL submitted individual reply comments that highlight the importance of net neutrality to ARL institutions, urges the FCC to maintain protections under Title II (noting that it is the clearest path to regulatory certainty), and noting the importance of an open Internet to the First Amendment.

ARL’s reply comments note that while ensuring strong net neutrality rules consistent with joint principles released by library and higher education groups are the primary concern,

…if the FCC reclassifies, the resulting conundrum is this: if the FCC attempts to adopt strong rules, the stronger they are the more judicially-vulnerable they are. If the FCC responds to this appellate vulnerability and adopts relatively weak rules, it shifts the risk to consumers, exposing them to abusive ISP practices.

An open Internet is critical to the functioning of the Internet today, including for the cutting-edge research, platforms, innovations and collaboration that takes place at ARL members. In addition to several examples of the importance of an open Internet to ARL’s work and services included in the reply comments, additional examples have been collected on this page. Net neutrality enables libraries to provide access to vast troves of data, facilitate discovery, preserve and share culture and information, provide interactive connected spaces and classrooms, facilitate data management, offer online courses, and provide international, interconnected wifi access.

Read ARL’s press release here.

Battle for the Net: Day of Action to Save Net Neutrality

Today, July 12, 2017, ARL is joining thousands of websites and tens of thousands of individuals in participating in an Internet-wide Day of Action to Save Net Neutrality. This day of action is designed to draw attention to the importance of net neutrality and the current threats an open Internet faces due to new leadership at the Federal Communications Commission (FCC).

The strong net neutrality rules we currently have in place, set forth in the FCC’s 2015 Open Internet Order, were fought for and won by millions of people and organizations who took action by submitting comments to the FCC in support of strong rules protecting the Internet. ARL joined with other library and higher education organizations to submit principles, comments and reply comments pointing out the importance of net neutrality to our institutions and users. The FCC’s 2015 Open Internet Order provided clear rules, grounded in a strong legal basis, when it reclassified

All Internet users should be concerned about the FCC’s efforts to roll back net neutrality. Without strong rules to preserve an open Internet, service providers will have the ability and incentive to block, throttle, or engage in paid prioritization, drastically changing the character of the Internet from an even playing field to one in which only the wealthy can afford to have their content prioritized. Strong net neutrality rules are essential to protect online free speech and innovation.

You can take action by contacting the FCC and Congress, which can be done easily at Battle for the Net. The Internet should not be divided into “fast lanes” and “slow lanes.” It should remain open, so that all voices and content may have equal footing, rather than elevating only the voices of those who have the means and are willing to pay a premium.

Today’s Day of Action will harness the power of the Internet to make sure that ordinary Internet users can make their voices heard and a wide range of organizations will be participating, from library groups such as ALA and ARL, to civil society groups like Demand Progress and EFF, to social media sites like Twitter and Snapchat, to video hosting or streaming sites like Netflix and Vimeo, to journalism sites such as The Nation and Daily Kos, to companies like Amazon and Dropbox. A full list of participants is available on the Day of Action page.

Celebrating 20 Years of Internet Free Speech

Today marks the 20th anniversary of the Supreme Court of the United States’ decision in Reno v. ACLU, a case that determined that certain provisions of the Communication Decency Act (CDA) – which sought to govern speech online – violated the right to free speech. This decision was a landmark decision, the Court’s first about the Internet and applied the same freedom of speech rules for print to speech on the Internet (both of which are more open than TV or radio broadcasts).

The CDA was designed to protect children from “obscene or indecent” content. However, because of the breadth and vagueness of the provisions, the Court found that the CDA could also suppress speech to adults:

We are persuaded that the CDA lacks the precision that the First Amendment requires when a statute regulates the content of speech. In order to deny minors access to potentially harmful speech, the CDA effectively suppresses a large amount of speech that adults have a constitutional right to receive and to address to one another.

The Court found that less restrictive alternatives could be used to achieve the same goal of reducing explicit content to children. The CDA, however, resulted in “an unnecessarily broad suppression of speech addressed to adults.”

Reno v. ACLU is a decision that gave us the Internet as we know it today. One that is free and open, a modern town square. Celebrating this landmark ruling brings to mind a number of related issues that are at the forefront of discussions today. While Reno v. ACLU gave us a ruling that established that freedom of speech applies online, we are still fighting for strong net neutrality rules that keeps the Internet open to all and does not favor one speech over another. While the Supreme Court’s Reno v. ACLU decision applied the same First Amendment protections to online speech as print, we are still fighting for reforms to the Electronic Communication Privacy Act to ensure that the same Fourth Amendment protections that apply to print apply to online communications.

Let’s celebrate 20 years of Reno v. ACLU, but remember that there is still work to be done to ensure that Constitutional rights apply with the same force in the digital world as it did in an analog one.

ICYMI: New Advocacy and Public Policy Update

On May 19, 2017, ARL released its latest Advocacy and Public Policy Update. The topics covered in this update include various copyright issues (Register of Copyrights bill, Copyright Office study on moral rights, Copyright Office rulemaking on modernizing copyright recordation, and numerous amicus briefs filed), LSU v. Elsevier, appropriations, access to and preservation of government data, net neutrality, developments on trade agreements, and issues related to immigration and border control.  The full update is available here.

 

ARL Joins Higher Education and Library Groups to Oppose Changes to Net Neutrality Rules

On May 18, 2017, the FCC voted 2-1 to move forward with its notice of proposed rulemaking to roll back net neutrality protections that were set forth in the agency’s 2015 Open Internet Order. The FCC appears to want to reverse course on Title II reclassification, which provided the strong legal basis for the no blocking, no throttling and no paid prioritization rules, and potentially give enforcement oversight to the Federal Trade Commission (FTC) instead. ARL joined higher education and library groups in issuing the following statement:

May 18, 2017

No Changes to Net Neutrality Law Necessary, say Higher Ed and Library Groups

Since the passage of the FCC’s 2015 Open Internet Order, internet users have benefited from strong and enforceable net neutrality policies, which are essential to protecting freedom of speech, educational achievement, and economic growth for all Americans. Today’s vote puts those protections in jeopardy.

Libraries and institutions of higher education are leaders in maximizing the potential of the Internet for research, education, teaching and learning, and the public good.  In the modern era, a free and open internet is essential to our public missions. The current net neutrality rules – no blocking, no throttling, and no paid prioritization, backed by a general conduct standard to ensure net neutrality adapts as the Internet evolves – generated unprecedented public support, and the validity of both the rules and the process that produced them has been affirmed by the DC Circuit Court.

Given all these factors, we believe no changes to the FCC’s 2015 Open Internet Order are necessary.  We urge the Commission to rescind the NPRM approved today and work with all stakeholders to enhance flexibility and innovation within the existing framework. Application of the rules to this point has demonstrated that the Commission can manage the regulatory environment for Internet access without undermining the sound, legal basis for network neutrality.

Should the FCC continue down the path proposed in the NPRM, however, the higher education and library communities would again draw the Commission’s attention to the network neutrality principles for which we have consistently advocated. We believe the Commission can and should frame any efforts to support an open Internet around these principles, and we will work through the rulemaking process to sustain strong network neutrality rules based on them.

We look forward to working with the FCC on ensuring that the Internet remains open.

The organizations endorsing this statement are:

American Association of Community Colleges (AACC)

American Association of State Colleges and Universities (AASCU)

American Council on Education (ACE)

American Library Association (ALA)

Association of American Universities (AAU)

Association of College & Research Libraries (ACRL)

Association of Public and Land-grant Universities (APLU)

Association of Research Libraries (ARL)

Chief Officers of State Library Agencies (COSLA)

Council of Independent Colleges

EDUCAUSE

National Association of College and University Business Officers (NACUBO)