TY - JOUR
AU - Lentz,, Becky
AB - Abstract This article offers a framework for studying the historicity of the contemporary debate about network neutrality in the United States by drawing on the theory of intertextuality. Contrary to the popular notion that the idea of “neutrality” first appeared in 2002, the article traces the term back to the 1960s when the Federal Communications Commission took up the problem of convergence or “compunications” in the Computer Inquiry proceedings. The article closes with some reflections about how an intertextual perspective informs study of policy as a constitutive discursive practice. Introduction This article takes a discourse theory approach to the analysis of a catalytic episode in the U.S. network neutrality debate, highlighting the constitutive role that definitions play in policy-making processes. Definitions are particularly important in telecommunications policy-making where decision makers draw painstakingly careful distinctions between different types of services that result in some being more regulated than others. These differences matter given that regulated services often carry with them more public-interest obligations than less-regulated services. A key example of the former is common carriage, a service by telecommunications providers similar to that of the postal service: a guarantee of nondiscriminatory carriage of communication. Policy-makers' efforts to codify definitions in legislation and in federal agency rule-making become pivotal political moments in the linguistic work of policy advocates, each lobbying to fix meaning in ways that suit specific political, economic, or social goals. Thus, in the discursive politics about issues like network neutrality, definitions function as what Laclau and Mouffe (1985) refer to as nodal points: partial yet “privileged condensations of meaning … on a particular set of signifiers” (Howarth, 2000, p. 110). In view of the importance of definitional work, this article argues that an intertextual perspective brings to analysis of the network neutrality debate a critically important historical dimension. For example, if we agree that policy-making is largely a communicative practice, and that policy change is rooted in language (that words matter), then we can also observe in concrete ways how the incrementalism often attributed to policy change actually works in linguistic practice—how definitional work unfolds over time, how it evolves and changes, and how excavating prior discursive work serves a strategic purpose in the present moment. Indeed, policy advocates' insights into the locations of strategically useful linguistic sediment become a form of “necessary knowledge” for participation in a policy-making process. Depositing one's own words, ideas, and concepts into an official policy record inscribes meaning that is available for later retrieval. Thus, researching telecommunications policy change requires attending to the evolution of language in policy artifacts. As one prominent legal discourse scholar observes, While language is central to all human affairs, it is particularly critical in the law. Physicians work with physical substance and entities; in contrast, the work of lawyers and judges is symbolic and abstract. In a most basic sense, law would not exist without language. (Danet, 1985, p. 273) Attending to the historical evolution of language in supposedly “new” media policy debates like network neutrality is important given that terms often appear to emerge de novo, for example, Hart's (2011) claim that the debate began around 2002 when a young law professor named Tim Wu coined the phrase “network neutrality.”1 Briefly, network neutrality has to do with a variety of technical concerns about telecommunications infrastructure, with the result being the provision of nondiscriminatory broadband services. According to the Congressional Research Service (CRS), there is no agreed-upon definition of net neutrality. Even so, the CRS maintains that “most agree that any such definition should include the general principles that owners of the networks that compose and provide access to the Internet should not control how consumers lawfully use that network, and they should not be able to discriminate against content provider access to that network” (Gilroy, 2012). While this may sound purely technical to some, Blevins and Shade (2010) assert that network neutrality is “the telecommunication policy issue of the 21st Century” (p. 1), given the fundamental importance of broadband infrastructure to the online flow of ideas and information in democratic societies. Public interest policy advocates play an essential role in ensuring that government delivers on that promise (Chester, 2008; Hackett & Carroll, 2006; Klinenberg, 2007; McChesney, Newman, & Scott, 2005; Mills, 2004; Opel, 2004; Rodriguez, Kidd, & Stein, 2009). Yet, achieving this is only possible if the regulatory process includes meaningful channels through which citizen and consumer demands can be voiced. One particularly important venue for this is a federal regulatory proceeding: an opportunity for a variety of actors (scholars, industry, and public interest lobbyists, citizens, and consumers) to provide comments (and replies to others' comments) to the regulatory agency considering a change in policy. In the United States, the network neutrality debate gained momentum after 2002 (Frieden, 2008; Hart, 2011; Sandvig, 2006; Wu & Yoo, n.d.; Yoo, 2004) as policy-makers considered further deregulating broadband services offered by cable providers, ostensibly to spur economic growth, competition, and innovation. Broadband services provided by regulated common carriers had been defined for some time as “telecommunications” services. However, responding to industry lobbying and the increasing convergence of telephone, cable, and other technologies in 2002, the Federal Communications Commission (FCC) decided to classify cable broadband as an “information” service, freeing it from obligations to function as a common carriage service, even though cable modem service depends on an underlying telecommunication service (FCC 02-77). In efforts to “level the playing field” across media platforms, three years later, in 2005, the FCC reclassified the broadband offered by phone companies using digital subscriber line (DSL) technology as information services as well (Wireline Broadband Order, FCC 05-150). A year later, the FCC did the same with “broadband over power lines” (BPL) (FCC 06-165), and wireless broadband in 2007 (FCC 07-30).2 Histories of the debates surrounding these reclassification decisions describe the various challenges that industry and public interest advocates mounted in response to related legislative, regulatory, and judicial decisions. The FCC's successive cascade of reclassification decisions received much scholarly and press attention, making net neutrality a catalytic issue for many concerned about erosion of the historic firewall between regulated and unregulated services. Both simultaneous and subsequent to key regulatory actions, debate has continued about how to define broadband services, leading to industry-led court challenges and decisions, congressional actions calling into question the FCC's authority to regulate broadband providers, and efforts by civil society groups to weigh in on behalf of citizens and consumers. Included in some of this literature, especially those filings submitted to the FCC in response to requests for comments on its various reclassification decisions, are references to important prequels to this entire debate: The Computer Inquiries—a set of three successive regulatory proceedings that began in 1966 and continued through 1989. The Inquiries were taking place at the same time as the dismantling of AT&T's monopoly over telephone service and the growth and expansion of cable television. One contemporary document, in particular, referred to the Inquiries as the “computer inquiry regime” (Federal Communications Commission, 2005b). Today, many arguments either for or against network neutrality necessarily invoke the Inquiries as antecedents in the creation of what we now understand as “information services” (Crawford, 2009). The point to be made here is that excavation of these earlier regulatory artifacts reveals that the definitional disputes in the network neutrality debate are not new. Attempts by the FCC to distinguish between basic telephone service and more advanced services like call forwarding or voicemail that require the integration of data processing technology (computers) into telecommunications networks goes back at least to the 1960s. Furthermore, scrutiny of these earlier regulatory proceedings reveals an effort that endures today: parsing definitional meanings. As recorded by the nameless scribes of FCC decisions, efforts to delimit the features and functions belonging to telephone services as opposed to computer technologies continue. We can view these efforts as representing for the network neutrality debate what Krippendorff (2011) describes as “the literal heritage of a discourse” (Federal Communications Commission, 2005a). Seen as a politically charged discursive practice, FCC rule-making (Kerwin & Furlong, 2010) inscribes meaning by codifying definitions. These codifications form the linguistic sediment—a strategic discursive resource (Hardy, Palmer, & Phillips, 2000)—that serves attempts by policy-makers and policy advocates alike to manipulate nodal points in an effort to fix meaning in later policy debates.3 With attention to this kind of strategic linguistic work, this article features an important episode in the network neutrality debate that illustrates the powerful constitutive role that definitions play in telecommunications policy-making. More specifically, I apply literary and media studies approaches to the study of intertextuality to observe the (re)production of meaning-making in telecommunications rule-making, illuminating the important wording and rewording of telecommunications service definitions. The remainder of the article proceeds as follows. First, I provide relevant background on telecommunications policy. I then introduce the notion of intertextuality in critical discourse theory to investigate discursive change, and explore its application to telecommunications policy change drawing on a model of vertical and horizontal intertextual relations advanced in media studies. Using examples of how the FCC depends on its textual history to shape its rulings, I show how incremental shifts in the evolution of regulatory definitions actually undermine efforts in the contemporary moment to establish, much less maintain, nondiscriminatory broadband networks. The article closes with some reflections about what an intertextual perspective contributes to the study of telecommunications policy change. Background In 1986, the FCC issued a Report and Order that serves as an important constitutive moment for the contemporary network neutrality debate. As already noted, the Computer Inquiries are regulatory antecedents to the network neutrality debate because in 1980, the FCC created a new unregulated category of telecommunications called “enhanced services”. Collectively, the Inquiries focused on the problem of convergence, or “compunications,” a term the FCC used to describe the increasing intermingling of telephony and computing. The Computer Inquiry record traces the evolution of definitions related to distinctions between content and carriage—the framework upon which much of the current debate about network neutrality rests (Zarkin, 2003a).4 The FCC's 1986 Report and Order is also the first place in those Inquiry documents where the term “neutral” appears. In everyday speech, we generally consider “neutral” to mean something that has no strongly marked or positive characteristics or features, does not take sides, is nonaligned, and is neither beneficial nor harmful. The term suggests an impartial, or unbiased state or person; a disengaged position. In the Computer Inquiry document of interest here, the term “neutral” plays an ambiguous role, similar to that of an “empty signifier” (Laclau and Mouffe, 1985). For example, Howarth (2000) observes how “signifiers like ‘justice’ or ‘blackness’ function to unify and sediment a wide range of practices and discourses” (p. 118). Jorgensen and Phillips (2002) see these as “empty signs … [that] mean almost nothing by themselves until, through chains of equivalence, they are combined with other signs that fill them with meaning” (p. 49). An example is the notion of a “liberal democracy” that acquires meaning through its association with phrases like “free elections” and “freedom of speech.” In the FCC's 1986 Report and Order we observe the precision used to discuss the notion of neutrality in mostly adjectival terms. For example, is a particular telecommunications service inherently neutral, and if so, in what sense is it neutral? Or is neutrality merely a characteristic that the FCC attributes to a specific service, and if so, what part of that service? Finally, what determines such neutrality? We also observe how references to the concept of neutrality echo distinctions made throughout the history of communication regulation in the Unites States (originally modeled on transportation policy) between content and conduit: the message and that which carries the message. In telecommunications policymaking, companies that transport communication have traditionally been regulated as content-neutral “common carriers” (Crawford, 2009; Sandvig, 2006): any person engaged as a common carrier for hire, in interstate or foreign communication by wire or radio or in interstate or foreign radio transmission of energy, except where reference is made to common carriers not subject to this Act; but a person engaged in radio broadcasting shall not, insofar as such person is so engaged, be deemed a common carrier. (Communications Act of 1934, 1934, sec. 47 U.S.C. 153) For a service to be considered a content-neutral common carrier, the regulator must find a way to distinguish between a purely transport (or carriage) service and a content service. In regulatory practice then, the term “neutral” plays an important constitutive role in this regard, as we see from the following examples. The first time the term “neutral” appears in the 1986 Report and Order is in paragraph 7 as part of a discussion about several regulatory approaches the FCC had proposed a year earlier (see Federal Communications Commission, 1985) to a computer-related function known as “protocol processing.” Briefly, the FCC defined protocol processing as something technically and functionally similar to a “basic communications” type of service.5 The FCC uses the term “neutral” in this passage adjectivally to describe a specific type of protocol processing, deemed already to be a subset of unregulated “enhanced” services, which it refers to as “a neutral ‘adjunct’ service” (Federal Communications Commission, 1986a, para. 7). While the Report and Order does not actually define the term neutral, its association of neutral with the adjective “adjunct” suggests something that is incidental, ancillary, attached to, or supplemental to something else. With “neutral” as the linguistic modifier for “adjunct,” we can assume that a “neutral adjunct service” is something that is neither beneficial nor harmful as well as something that is merely supplemental rather than essential (the former being a definition of “adjunct”). The next time the term neutral appears is in paragraph 266 in a discussion about what kind of regulatory treatment, if any, the FCC should assign to protocol processing functions (Federal Communications Commission, 1980). Yet, in a later Computer Inquiry document, the FCC considered that one way to view protocol processing was as a type of adjunct regulated service as opposed to a function; something that is “essentially neutral for regulatory purposes since they [protocol processing functions] facilitate communications and do not change the information content of a subscriber's message or data” (Federal Communications Commission, 1986a, para. 266). Note the clarification added here. Because they are ostensibly “neutral,” protocol processing functions can be considered supplementary (adjunct) to regulated services. A third passage referencing neutrality in the same 1986 Report and Order appears 24 paragraphs later in a discussion about the “essentially ‘neutral’” function of protocol processing. This passage also includes discussion about a subset of the protocol processing function referred to as “protocol conversion.”6 In this passage, the FCC considers whether it should label either function (protocol processing or protocol conversion) as “essentially ‘neutral’” or as an enhanced (and thus unregulated) service (Federal Communications Commission, 1986a, para. 290). The passage concludes that neutral functions could belong in either a regulated or an unregulated category of service, in other words, “used in conjunction with either basic or enhanced services” (para. 290). Recall that basic services are regulated whereas enhanced services are not. A fourth mention of neutrality appears in paragraph 297 where the FCC reasons further that “from a technical, functional perspective, protocol processing may be a neutral function” (Federal Communications Commission, 1986a, para. 297). Then, in paragraph 298, we observe the FCC reasoning how it can, therefore, change its 1980 ruling defining “enhanced” services by tweaking its wording of a particular clause in that definition (emphasis added): A regulatory approach based on the analysis that protocol processing is a neutral function, which can be provided as an adjunct to either basic or enhanced services, could be implemented by eliminating or modifying the first clause of section 64.702(a) to delete these neutral functions, or some identifiable subset of such functions, from the enhanced services definition. (Federal Communications Commission, 1986a, para. 298) So what do these passages concerning the notion of neutrality in a 1986 FCC Report and Order have to do with the contemporary network neutrality debate, other than to show how concerns about the neutrality of telecommunications services are not new—that they enjoy a protracted history that contemporary accounts may not always acknowledge? The answer, in short, is this. All five passages illustrate the signifying roles that definitions play as the “privileged condensations of meaning” mentioned earlier. They also allow us to observe what Jorgensen and Phillips (2002) suggest is a primary task of discourse analytical work, that is, to “focus on specific expressions in their capacity as articulations [and ask] what meanings … they establish by positioning elements in particular relationships with one another, and what meaning potentials … they exclude” (p. 29). Each of the featured passages attempts to reduce possibilities and remove ambiguities, producing what we can observe are provisional closures in meaning in the policy record. As I will argue, given that much regulatory writing is referential, the key for policy actors is knowing the textual locations of such linguistic closures. Understanding “neutrality's” linguistic past is necessary to (re)shape its semantic future. To his credit, Wu timed a 2002 memo and subsequent article (Wu, 2003) to coincide with public discussions underway at the time about open networks (Cooper, Lemley, Lessig, & Stanford University, Center for Internet & Society, 2004).7 His work rehabilitated concerns about the common carriage principle in telecommunications networks that had existed well before the breakup of AT&T's monopoly in the 1980s. Wu's work also secured the idea of neutrality in the minds of a new generation of public interest policy advocates who grew up taking cell phones and Internet access largely for granted. It is not clear, however, how familiar these newer policy advocates are with policy struggles that brought those services into being in the first place. Be that as it may, to make a case either for or against whatever one might define network neutrality to mean requires knowing something about key episodes of the concept's legislative, judicial, and regulatory past: when and how definitions are crafted for one purpose, for example, unbundling monopoly services, and how those same definitions are summoned again for possibly a completely different purpose, namely, rebundling services. Key then, as well as now, is whether companies that control telecommunication networks should be allowed to influence lawful content or to discriminate in how they transport that content using their electronic network facilities. Intertextuality reconsidered Policy advocates both for or against network neutrality engage in a variety of strategies and tactics to influence decision makers charged with crafting and implementing new policies or improving existing ones. Those most engaged in detailed policy debates often voice their concerns and positions through textual practices by providing testimony in public hearings, filing comments in regulatory proceedings, initiating legal challenges, educating their constituencies (including journalists), and conducting policy research to inform decisions that include the codification of concepts like neutrality. Such work involves considerable communicative labor, notably writing, which is why intertextual analysis offers a tool for studying many of the rhetorical strategies involved in advocates' work. An analytical focus on language also foregrounds how prominently writing figures in the work of unnamed FCC staff as well as lobbyists and representatives of civil society organizations. Extending Bakhtin's work, Julia Kristeva (1986) defined intertextuality as “the insertion of history (society) into a text and of this text into history” (p. 39).8 She extended what Bakhtin observed, that “an utterance is a link in the chain of speech communication, and it cannot be broken off from the preceding links that determine it both from within and from without, giving rise within it to unmediated responsive reactions and dialogic reverberations” (Bakhtin, 1986, p. 107). Critical discourse theory scholar Norman Fairclough has shown how intertextuality is used in the discursive practices of institutions (a mesodimension of analysis) to mediate, bridge, and link texts (a microdimension) to their social contexts (a macrodimension) (Fairclough, 1992, p. 195).9 Fairclough also notes how discourse conventions (genres) serve as core resources that text producers and interpreters mobilize in text creation and reception processes. In this view, we can examine how discourse practices that support FCC policy-making adhere to conventions dictated by administrative procedure (Administrative Procedure Act of 1946). Administrative procedure as a generic practice is particularly visible in an overt (manifest) form of intertextuality, wherein texts draw explicitly upon other texts (Fairclough, 1992). Indeed, regulatory writing makes extensive use of citations to other documents, often in lengthy footnotes, representing what Fairclough describes as the representations of other discourses. Fiske (1987) points out in his work on popular media that intertextual relations can be viewed temporally in two dimensions. The horizontal (synchronic) dimension features relations to other existing texts, whereas the vertical (diachronic) dimension highlights historical development of an individual text. Jensen elaborates on Fiske's work on temporality (Figure 1), noting how the horizontal axis captures “the transfer and accumulation of particular meanings over historical time, as preserved in the metaphors, characters, and styles of traditional arts as well as popular media.” In contrast, the vertical axis “operates during a more delimited time period, but extends across several media and social contexts” (Jensen, 2008). In Fiske's two-dimensional view of intertextuality, primary texts serve as the center of analytical attention given their unique productive capacity: their role as “carriers of significant insight in their own right” (Jensen, 2008). An example is Fiske's consideration of a feature film as a primary text and its accompanying publicity, reviews, and criticism within the media system as secondary texts. Fiske treats the film's reception by critics and audiences as tertiary texts. Figure 1 Open in new tabDownload slide Two axes of intertextuality (Jensen, 2008) Figure 1 Open in new tabDownload slide Two axes of intertextuality (Jensen, 2008) In the remainder of this article, I apply these perspectives about intertextual relations to telecommunications policy-making using a catalytic artifact in the network neutrality debate as an example (Figure 2). In my adapted framework, the horizontal axis features intertextual relations between and among earlier related policy texts, genres, figures, and themes produced by state actors. The vertical axis features intertextual relations contributing to the historical development of a particular primary text, that is, its diachronic lineage that may draw on secondary and tertiary artifacts produced by nongovernmental actors. Figure 2 Open in new tabDownload slide An intertextual perspective on telecommunications policy Figure 2 Open in new tabDownload slide An intertextual perspective on telecommunications policy In the example provided here, I have situated the FCC's 2002 Declaratory Ruling that reclassified cable modem services as an information, not a telecommunication service, at the intersection of both temporal dimensions as a primary policy artifact with productive (constitutive) capacity. The horizontal axis shows that this Ruling is the third of five artifacts that comprise an FCC regulatory proceeding begun in 2000 (GN Docket No. 00-185). To the left of the primary artifact, we see the two documents that preceded that Ruling. To the right, we see the two artifacts that followed the Ruling. The vertical axis shows the 2002 Ruling in relation to some of the secondary and tertiary activities involved in its production and reception.10 In this view of telecommunications policy-making, primary artifacts such as the 2002 Ruling have constitutive capacity; they contain specific passages that attempt to fix meaning, and thus trigger, evoke, and respond to other meaning-making work represented on both the horizontal and vertical axes. This way of depicting policy-making enables us to consider how a web of textual relations contributes to the construction of a particular policy text. This framework also helps us observe the historicity of primary policy artifacts by noting the intertextual relations they share with other prior and subsequent artifacts. On the horizontal axis, earlier and later artifacts might include FCC memos, rulings, or policy statements in addition to earlier and later legislation or court cases. The vertical axis in this framework captures communicative activities according to their proximity to policy-making processes, for instance, the work of policy advocates, think tanks, academic researchers, industry lawyers, advocacy groups, and the press, among many others. More specifically, secondary artifacts represent the outcome of direct engagement with the actions and decisions of policymaking actors (e.g., Congress, courts, and federal agencies). Examples include filings in response to an FCC request for comments, or testimony at a public hearing, or even meetings with FCC staff. Tertiary artifacts, on the other hand, represent indirect forms of engagement with policymaking actions, for example, the work of journalists, bloggers, advocacy coalitions, community activists, citizen and consumer groups, or industry lobbyists. Tertiary activities, in other words, do not directly engage with a policy-making process, even though policy processes may influence them, and vice versa. Tertiary activities include critiques, reactions, reports, summaries, interpretations, evaluations, and assessments of policy-making actions and decisions. In addition, like secondary activities, tertiary activities might draw on linguistic sediment contained in a related horizontal or vertical intertextual chain. Differentiating between secondary and tertiary activities helps illuminate different types of policy-related work. An intertextual perspective on policy change sheds light on interactions between and among different types of policy advocacy labor. It also offers a way to observe how policy actors adapt their discursive practices over time. Policy-making and policy advocacy depicted in this way helps identify critical discourse moments (Chilton, 1988), instances where primary, secondary, and tertiary activities reflect discursive struggle over empty signifiers like “neutral,” as in the 1986 document discussed earlier. We can also observe how earlier artifacts such as the 1986 document get taken up later, for example, in the FCC's 2002 Declaratory Ruling. In both documents, discussion about definitions function as nodal points: “privileged signifiers” that link historical elements of a discourse together. Yet such signifiers only “temporally construct and stabilize discourses” (Van Brussel, 2010, pp. 3, 15), given that they are merely contingent articulations. A closer look at key episodes of the network neutrality debate allows us to observe these types of discursive dynamics. Indeed, some of the most privileged signifiers in telecommunications policy-making are definitions for technical functions like “protocol processing” discussed earlier. This is because those definitions help regulators determine whether a particular service is regulated or not. For example, in 2002, the “year of the telecom meltdown” (Oesterle, 2003), the FCC's justifications for classifying cable modem service as an “information service” instead of a “telecommunications service” necessarily drew upon reasoning in earlier congressional, judicial, and regulatory actions related to distinguishing between basic versus enhanced services. A casual reader might think the difference between these two terms is merely rhetorical. A lawyer might consider the difference a technical, specialized legal distinction. However, this article seeks to point out the constitutive nature of these concepts and how their meaning evolves out of the intertextual relations between and among texts over time. What follows, then, are selected examples of these relations from the FCC's 2002 Declaratory Ruling (Figure 2), an important nodal point in the evolution of the U.S. network neutrality debate.11 Earlier texts on the horizontal axis include landmark court cases (United States District Court for the District of Columbia, 1982), regulatory proceedings that began in the 1960s with the first Computer Inquiry (Federal Communications Commission, 1966), the evolution of cable television resulting in the Cable Acts of 1984 (Cable Communications Policy Act of 1984) and 1992 (Cable Television Consumer Protection and Competition Act of 1992), and the rewriting in 1996 of the Communications Act of 1934 (Telecommunications Act of 1996). Inserting telecommunications history into texts and texts into telecommunications history Public officials and their staff engage daily, as a discourse community, in writing practices that involve making a variety of linguistic choices about how history will inform its decisions. As already argued, an intertextual perspective on regulatory practice allows us to observe traces of this practice. Since 2002, the FCC has taken a series of decisions that classify cable, DSL, wireless, and BPL service providers as information services, as opposed to telecommunications services. This has caused concern among public interest advocates about potential discrimination in broadband network services. Similar to the way the postal service works in the public sector, for most of the 20th century in the United States, the common carriage obligations of telecommunication providers guaranteed nondiscriminatory electronic transport of message content. Providers of “telecommunications services” are subject to regulation as Common Carriers; those providing information services are not. Unlike public postal carriers, however, common carriers in the telecommunications sector are commercial providers of services essential for access to the Internet. This is why the common carriage principle has been central to discussion of network neutrality (Crawford, 2009; Sandoval, 2009; Sandvig, 2006; Wu, 2007) and why the FCC's 2002 Cable Ruling bears attention as a nodal textual artifact. The Ruling opened the door for the FCC to designate other providers, regardless of media platform (cable, DSL, wireless, or broadband delivered over a power line referred to as BPL) as providers of information services, not telecommunication services. The distinction between the two is subtle but critically important for the network neutrality debate. For example, an information service offers a capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information via telecommunications and includes electronic publishing, but does not include management, control, or operation of a telecommunications system or the management of a telecommunications service (Telecommunications Act of 1996, 1996). In contrast, a telecommunications service is the offering of telecommunications for a fee directly to the public, or to such classes of users as to be effectively available directly to the public, regardless of the facilities used (Telecommunications Act of 1996, 1996). Scrutiny of both definitions reveals a fine-grained distinction that forms the essence of the network neutrality debate, at least in the United States. A broadband provider offers services that require an underlying layer of regulated telecommunications. An enhanced service provider is permitted to produce, control, or change the information (or content) it offers to its customers. Hairsplitting discussions in the regulatory record about the essence of information versus telecommunications services began in the 1960s with the FCC's Computer Inquiries mentioned earlier. Each is identified by a unique “docket” number, providing a way to organize chronologically all of the primary-level (referring to Figure 2) FCC decisions and actions associated with each docket proceeding as well as all of the related secondary artifacts filed by outside parties. For the Computer Inquiries, when viewed on a horizontal axis, we would see a series of 23 artifacts grouped into three dockets. Going forward in time, we would also eventually see the FCC's 2002 Ruling as the third of five primary artifacts contained in another docket referred to as GN Docket No. 00-185 (Figure 2). This temporal placement situates the 2002 Ruling within a trajectory of prior as well as subsequent FCC orders, notices, and rulings concerning carriage versus content services. As a way to visualize where the FCC's 2002 Declaratory Ruling fits into this larger history, we might situate that decision as a primary artifact of interest on the horizontal axis shown in Figure 2. This placement enables tracing the evolution of pivotal definitions through artifacts that go back much further than contemporary accounts of the debate might lead us to believe. While Hart (2011) rightly situates the origins of the network neutrality debate in the United States with “digitization” (p. 419), digitization became a topic of conversation at the FCC in the Computer Inquiries. Even so, Hart situates the birth of the network neutrality debate as much more recent, noting a letter sent in 2002 to the FCC in the network neutrality debate called the Coalition of Broadband Users and Innovators (CBUI).12 In the letter, according to Hart, the phrase “network neutrality” appeared: a phrase the CBUI apparently picked up from the work of law professor Tim Wu mentioned earlier (Hart, 2011, p. 420). Yet, as already suggested, an intertextual perspective on the same regulatory events situates the origins of the debate much earlier. Awareness of, and access to, this “prior knowledge” provides a competitive rhetorical advantage in the network neutrality debate, wherein advocates can exploit the ambiguity of prior definitional work to their advantage. Using Figure 2 as visual reference, consider the CBUI's 2002 letter as one among hundreds of other artifacts submitted to the FCC by policy actors in response to the FCC's 2002 Declaratory Ruling classifying cable modem service as an information service (Federal Communications Commission, 2002). To be sure, numerous other policy artifacts preceded this one, for example, other regulatory, judicial, and legislative actions as well as comments, and even replies to those comments, from hundreds of secondary actors. Yet, an intertextual perspective on one particular ruling allows us to observe how policy artifacts are already embedded within a larger discursive struggle over the meaning of various regulatory concepts like “neutrality”. Such a perspective also makes visible the diversity of textual artifacts that are invoked within determining passages of texts like the FCC's 2002 Ruling. Using that Ruling as just one instance of this system at work, we can observe precisely what Kristeva (1986) theorized about the relationship between history and textual artifacts (p. 39). As the following examples show, it is not surprising that the contemporary network neutrality debate is littered with references to earlier primary, secondary, and tertiary artifacts illustrating how policy-makers and policy advocates look back to statutes, court cases, and previous regulatory decisions to construct their arguments about presumably new issues. That this is such a selective process, however, that privileges certain ways of knowing and thinking about electronic media and their social, industrial, political, and technological role, is a different matter altogether. We need to attend to how this constitutive power chisels away any presumed neutral authority that the FCC has as a regulatory body even as we expect regulatory agencies to be evidence-based and independent of the political process. The FCC's 2002 Declaratory Ruling on cable modem service that is shown as a primary artifact in Figure 2 contains traces of definitional struggles in earlier FCC proceedings, legislation, and court cases. As the most pivotal of the five primary artifacts in the FCC regulatory proceeding, GN Docket No. 00-185, the Ruling considers how to treat high-speed Internet access over cable facilities. That proceeding began with a September 2000 Notice of Inquiry expressing concern about convergence related to high-speed telecommunications services. The Notice initiated an opportunity for the FCC to seek comments from outside parties about this concern. In response, the FCC received 332 filings (secondary artifacts), which included a combination of formal comments on the FCC's proposals, notifications of ex parte meetings with FCC staff, and other types of communication such as notifications of address changes.13 Next in the regulatory proceeding was a Public Notice in October 2000 extending that comment period for responses to the Notice just described. Following the Notice is the 2002 Declaratory Ruling, which also included within it a Notice of Proposed Rule-making. The Declaratory Ruling is a pivotal artifact not just because of its constitutive role in determining the status of cable modems as information services. It also triggered two other key government actions: a legal challenge (9th Circuit, 2003) seeking to overturn that decision (Federal Communications Commission, 2002) as well as a subsequent Supreme Court case in reaction to the result of that appeal (U.S. Supreme Court, 2005). The Supreme Court upheld the FCC's 2002 decision. The fourth artifact in the docket proceeding is a 2004 Memorandum sent by the FCC's Associate General Counsel to the FCC's Media Bureau Chief advising of two petitions that had been filed seeking Supreme Court review of an appellate court decision in this matter (Armstrong, 2004). The final artifact is an important 2005 textual Policy Statement that established linkages to several related regulatory proceedings, one of which dated back to 1995 (Figure 3). Figure 3 Open in new tabDownload slide Excerpt from 2005 Policy Statement showing linkages among dockets Figure 3 Open in new tabDownload slide Excerpt from 2005 Policy Statement showing linkages among dockets Taking a moment to look more closely at the third artifact in the Docket, the 2002 Ruling itself (a 75-page document), we observe in the Table of Contents that only paragraphs 31–71 comprise the actual Ruling mentioned earlier (Figure 4). Paragraphs 31–33 provide necessary background information; paragraphs 34–59 discuss the history of classifications for information and telecommunications services; paragraphs 60–69 focus specifically on a service classification called “cable service”; and paragraphs 70–71 discuss “Other Statutory Classifications.” Within this same document, paragraphs 72–112 initiate an entirely new regulatory proceeding titled “Broadband Access to Internet Over Cable Facilities” (CS Docket No. 02-52). The remainder of the Ruling document covers administrative details. Figure 4 Open in new tabDownload slide Table of Contents for 2002 Declaratory Ruling on Cable Modem Service Figure 4 Open in new tabDownload slide Table of Contents for 2002 Declaratory Ruling on Cable Modem Service Looking back at paragraph 33 we observe an example of the Fcc's explicit attention to intertextuality (emphasis added): 33. … we herein address the classification of cable modem service for purposes of the Act. Our analysis begins, as always, with the language of the statute. We then consider the factual record in this proceeding, and particularly the descriptions by cable operators and others of how cable modem service is provided today and what functions it makes available to subscribers and to ISPs. We conclude that cable modem service as currently provided is an interstate information service, not a cable service, and that there is no separate telecommunications service offering to subscribers or ISPs. The passage illustrates how the FCC first claims its authority to redefine a service by citing its enabling legislation, the Communications Act. The next paragraph 34 (Figure 5) then rehearses the entire history of the Computer Inquiries mentioned in footnote 139, an example of the kind of manifest intertextual relations described earlier: The term “information service” follows from a distinction the Commission drew in the First, Second, and Third Computer Inquiries (“Computer Inquiries”). Figure 5 Open in new tabDownload slide Excerpt from Fcc's 2002 Declaratory Ruling Figure 5 Open in new tabDownload slide Excerpt from Fcc's 2002 Declaratory Ruling Paragraph 34 opens with a review of relevant legislation: Because the classification of cable modem service turns on statutory interpretation, we begin with a review of relevant statutory definitions. (Federal Communications Commission, 2002, para. 34) We see next a review of definitions that will play a role in the FCC's rationale for reclassifying cable modem service. First the passage invokes the Telecommunications Act of 1996, which codified distinctions between a “telecommunications service” mentioned earlier and “telecommunications.” Next we see mention of the Act's definition of an “information service.”14 The first two footnotes (137 and 138) merely cite the Communications Act of 1934 as the source for the definitions being discussed. The third footnote, however, takes up more than three quarters of the page, itemizing in chronological sequence previous artifacts relevant to the evolution of these two definitions. As emphasized earlier, some of the most privileged signifiers in telecommunications policy-making are definitions of services, which have been defined, contested, revised, and codified in legislation or FCC rule-making. Footnote 139 illustrates the kind of meaning-making accomplished by selective reference to regulatory artifacts dating between 1971 and 1999. For example, the first of the two paragraphs that comprise footnote 139 begins with the following claim: The term “information service” follows from a distinction the Commission drew in the First, Second, and Third Computer Inquiries (“Computer Inquiries”). (Federal Communications Commission, 1971, 1980, 1986b) Following this is a lengthy string of citations for selected artifacts from the First, Second, and Third Computer Inquiry proceedings. For example, in a 1971 Order, the FCC defined two types of “hybrid” services that were used to semantically bridge the boundary separating regulated and unregulated services at that time (Federal Communications Commission, 1971, 1980, 1986a). Later artifacts continued this definitional boundary work resulting in a new category of service in 1980 called “enhanced” service. Key to the network neutrality debate is the wording of this 1980 definition (emphasis added): the term “enhanced service” shall refer to services, offered over common carrier transmission facilities used in interstate communications, which employ computer processing applications that act on the format, content, code, protocol or similar aspects of the subscriber's transmitted information, provide the subscriber additional, different, or restructured information; or involve subscriber interaction with stored information. Enhanced services are not regulated under Title II of the Act. (Federal Communications Commission, 1980) The highlighted clause was the focus of extensive discussion in the Third Computer Inquiry (Computer III) proceeding that began in 1985 (Federal Communications Commission, 1985). Enhanced services eventually became codified in legislation in 1996 as an “information service” in the Telecommunications Act (Telecommunications Act of 1996). In footnote 139 of the 2002 Ruling (Figure 5), we see reference to this legislative move (emphasis added): The Commission has confirmed that the two terms—enhanced services and information services—should be interpreted to extend to the same functions. (Federal Communications Commission, 2002, p. 23). Also included in footnote 139 are references to several court cases going back to 1973 and continuing through 1995 as well as references to artifacts of other FCC proceedings (e.g., CC Docket No. 85-229, also referred to as Computer III), and several related FCC dockets between 1990 and 1998. Footnote 139 also cites a critically important judicial decision: the historic 1982 Modification of Final Judgment (“MFJ”) that set in motion the breakup of AT&T's monopoly of the telecommunications industry (United States District Court for the District of Columbia, 1982). As it happens, the MFJ provided early versions of definitions for information and telecommunications services, which are very similar to those codified much later in the Telecommunications Act of 1996: “Information Service” means the offering of a capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information which may be conveyed via telecommunications, except that such does not include any use of any such capability for the management, control, or operation of a telecommunications system or the management of a telecommunications service. (United States District Court for the District of Columbia, 1982, p. 8) “Telecommunications service” means the offering for hire of telecommunications facilities, or of telecommunications by means of such facilities. (United States District Court for the District of Columbia, 1982, p. 8) However, the Telecommunications Act of 1996's definition of information service was not identical to the FCC's 1980 definition of an enhanced service: the offering of a capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information via telecommunications, and includes electronic publishing, but does not include any use of any such capability for the management, control, or operation of a telecommunications system or the management of a telecommunications service. (Telecommunications Act of 1996) Observe, however, how in footnote 139 of the 2002 Ruling the FCC uses the term “functions” as a possible hedging move to relate enhanced services to information services. In other words, enhanced and information services are not exactly the same things, but both are deemed to support the same purpose. In footnote 140 of the subsequent paragraph of the 2002 Ruling, we encounter another instance of intertextuality that seems to justify this attention to functionality as opposed to types of facilities being used to achieve a particular function (emphasis added): 35. None of the foregoing statutory definitions rests on the particular types of facilities used. Rather, each rests on the function that is made available. Accordingly, we examine below the functions that cable modem service makes available to its end users. The Commission's prior analysis regarding Internet access service informs our analysis. 140 Universal Service Report, 13 FCC Rcd at 11530 ¶ 59 (noting “Congress's direction that the classification of a provider should not depend on the type of facilities used … [but] rather on the nature of the service being offered to consumers.”) (Federal Communications Commission, 2002, para. 35, p. 24) Paragraph 36 then qualifies what the FCC means by different functions by citing yet another earlier artifact: the FCC's 1998 Universal Service Report (Federal Communications Commission, 1998), emphasis added: 36. In the Universal Service Report, the Commission found that Internet access service is appropriately classified as an information service, because the provider offers a single, integrated service, Internet access, to the subscriber. The service combines computer processing, information provision, and computer interactivity with data transport, enabling end users to run a variety of applications. In the Universal Service Report, the Commission concluded that “Internet access providers do not offer subscribers separate services—electronic mail, Web browsing, and others—that should be deemed to have separate legal status.” Rather, the Commission examined specific uses of Internet access in order “to understand the nature of the functionality that an Internet access provider offers.” (Federal Communications Commission, 2002, para. 36) This passage references a “single integrated service” that originates in a 1971 FCC Final Decision artifact (Federal Communications Commission, 1971). These example of intertextual relations illuminate how prior knowledge is mobilized for strategic purposes. Intertextual relations like these are highly selective; the text producer has drawn from historically available linguistic sediment only what is needed for the meaning-making task-at-hand. Absent, however, are other artifacts that reveal the malleable, iterative, and obfuscatory language that often lead to final versions of regulatory definitions (Lentz, 2011). In addition, one can only observe this historicity by evaluating a larger intertextual chain. Yet doing so is a daunting task. For example, the history of cable modem service that the FCC's 2002 Ruling references is itself linked to the entire legislative histories of the Cable Acts of 1984 and 1992. Both laws constitute necessary prior knowledge for understanding the role of cable technology (whether discussed as cable modems or as video programming services) as transport mechanisms in a telecommunications system. Going back to the 2002 Declaratory Ruling, we can observe in the second paragraph of footnote 139 (Figure 5) another example of the skill involved in selective excavations of regulatory linguistic sediment; the passage links information services to their purported prehistory as enhanced services (emphasis added). Recall that the FCC defined enhanced services in 1980 using language identical to the bolded text in this paragraph: These decisions drew a distinction between bottleneck common carrier facilities and services for the transmission or movement of information on the one hand and, on the other, the use of computer processing applications to act on the content, code, protocol, or other aspects of the subscriber's information. The latter are “enhanced” or information services. (Federal Communications Commission, 2002, footnote 139, p. 23) While not explicitly citing the 1980 definition for enhanced services, those who wrote the 2002 Declaratory Ruling were clearly already very familiar with the FCC's 1980 Final Decision of the Computer II proceeding (Federal Communications Commission, 1980). The same passage also references the FCC 1998 Universal Service Report (Federal Communications Commission, 1998) as well as FCC Docket No. 96-149, which contains 60 primary FCC artifacts dating between 1996 and 2004. As with the FCC's 2002 Declaratory Ruling, the FCC's Policy Statement (docket artifact #5) also inserts history into the then-present text using a footnote that mentions the 1956 Hush-A-Phone Corp. v. United States case (Federal Communications Commission, 2005a, p. 3). We also note reference to the Carterfone Device issue of 1968 (Wu, 2007), as well as the Preamble of the Telecommunications Act of 1996. Briefly, the Hush-A-Phone was a device invented by Harold Tuttle in the 1940s, and the Carterfone, a device created by Thomas Carter of the Carter Electronics Corporation in the 1950s. Both were designed to attach directly to a telephone, but this caused concern as it involved attaching a foreign device that could potentially threaten the integrity and security of telephone service. At that time, all telephone equipment had to be purchased directly from the monopoly provider AT&T. Tuttle tried twice unsuccessfully to get the FCC's approval to market his invention, once in 1951 and again in 1955. After appealing the second decision, in 1955, a court ruled in Tuttle's favor. The Carterfone, unlike the Hush-A-Phone, was an electronic device. However, like Hush-A-Phone, it did not connect electronically with AT&T's telephone system. Thus, Carter's request to market his device under the same rules as Hush-A-Phone sparked an FCC docket proceeding that eventually resulted in an FCC decision allowing “foreign” attachments if those devices did not actually “harm” the telephone network. In summary, the intertextuality evident in the artifacts of just one FCC docket (Figure 2) illustrates how the network neutrality debate continues to hinge on the FCC's contingent understanding of the ontological status of a particular electronic communication service. Is this essentially an “information” or a “telecommunications” service? Key here is the extent to which anything can be deemed “essentially” neutral. Scrutiny of these and many other intertextual references also illustrates the linguistic mechanisms used to sustain a porous semantic boundary between content (as an information service) and conduit (as a telecommunications service). In short, intertextual analysis suggests what regulatory experts already know: that there is no essential or inherent technological difference between these two concepts. Instead, regulatory definitions are the instruments needed to distinguish regulated from unregulated providers; struggles over these definitions is where we can locate the textual politics of network neutrality as critical nodal points in the ongoing discursive battle over meaning-making. Regulators, legislators, judges, and policy advocates labor over the construction and application of definitional nodal points as signifiers for a range of electronic capabilities that continue to evolve over time in ways that constantly seem to confound rigid definition. An intertextual perspective on policy change, thus, has the potential to highlight where such signifiers are produced and contested as well as how to track their transformations over time. In so doing, we can identify those moments in policy processes where discursive interventions become possible. In defining cable modem as an information service, the FCC's 2002 Ruling released cable modem service providers from common carrier obligations to provide nondiscriminatory broadband service. This action requires deep knowledge of earlier legislative, regulatory, and judicial actions. As we saw in the examples, previous definitions haunt the contemporary debate about network neutrality in that arguments about what network neutrality means, or whether it is a good or bad policy, demand skillful reference to selected definitions used in previous artifacts worthy of being excavated and reinserted into the temporal practice of policy-making. Primary artifacts serve as authoritative devices for such codifications, or stablized-for-now, contested signifiers. The combined effect of the FCC's 2002 Ruling and its 2005 Policy Statement set in motion several subsequent rulings that have since freed providers of broadband over wireline, wireless, and electrical power lines from stricter common carriage requirements (Federal Communications Commission, 2005b, 2007; Memorandum Opinion and Order, 2006). While these additional actions are outside the scope of this article, they deserve mention as additional sites for excavating examples of intertextual relations that show the ongoing contestation that takes place over definitions of services. Subsequent legislative, regulatory, and judicial actions combined with reactions and responses from secondary and tertiary actors since 2005 provide evidence that the discursive struggle over these definitions continues. Mapping this struggle along horizontal and vertical axes like those shown in Figure 2 allows us to observe how signifiers like “information” and “telecommunications” that replaced progenitors like “enhanced” or “neutral adjunct” services are placed by the FCC into further constitutive service. Paragraph 40 of the 2002 Declaratory Ruling is just one example of this constitutive work: 40. As stated above, the Act distinguishes “telecommunications” from “telecommunications service.” The Commission has previously recognized that “[a)ll information services require the use of telecommunications to connect customers to the computers or other processors that are capable of generating, storing, or manipulating information.” Although the transmission of information to and from these computers may constitute “telecommunications,” that transmission is not necessarily a separate “telecommunications service.” Conclusion This article has suggested a framework for thinking systemically and strategically about intertextual relations in the lineage of a policy debate, using network neutrality as just one example. Its goal has been to argue that we can only understand the dynamics of that debate if we recognize how it is informed by an institutional reservoir of language that is constantly being restocked with decisions, actions, and reactions. In this view, writers of contemporary policy artifacts selectively summon, activate, and marshal this intertextual sediment as they also make deposits into it for others to consider in future policy struggles. Insights into the specific locations of strategically useful intertextual relations become a kind of “necessary knowledge” for policy advocates who understand that depositing their own words, ideas, and concepts into the official policy record, or reservoir, is an essential achievement of their symbolic labor. An intertextual approach to analyzing the myriad primary, secondary, and tertiary artifacts of policy change reveals the dialogic nature of policy practice. Between the episodic interventions of tertiary actors organizing protests or marches, writing blog posts, facilitating web blackouts, signing petitions, or sending Tweets continues the day-to-day work of secondary policy actors who are submitting filings, engaging in ex parte communications with policy-makers, and providing testimony in public hearings. An intertextual perspective on policy change allows us to differentiate between these interdependent types of communicative labor, each being necessary but alone, insufficient to change policy. Studying the artifacts of policy-making in this light enables a dual focus on the interdependence of the primary, secondary, and tertiary actors who facilitate policy change through the production of artifacts. This serves to contextualize the contributions of a wider variety of policy actors, for example, the movement ephemera produced by tertiary actors, making more visible their labor in policy struggles. Considering the artifacts of policy-making in this way also adds a degree of rigor to the ways in which we attribute influence. For example, scholars like Wu and Lessig operate at both secondary and tertiary levels. They participate directly in policy change processes by providing comments, writing letters, being involved in ex parte meetings, or appearing at public hearings. Other scholars, however, might be involved less directly in policy processes; they may produce work that secondary and tertiary actors activate in their policy work. Thus, as noted earlier, differentiating between secondary and tertiary types of communicative activities helps illuminate how nonexperts engage and influence policy debates. An intertextual perspective on policy change also sheds light on the importance of prior knowledge—the historical knowledge required to participate in policy advocacy about complex issues like network neutrality. Furthermore, the intertextual perspective on researching policy change suggested here is flexible in its application as it recognizes the myriad types of institutions, issues, and contexts of policy change. The framework is also scalable: it can be used to examine micro-, meso-, and even macrolevel intertextual relations within a specific policy-making institution across different time periods. Using the FCC as an example, primary artifacts include those within a specific regulatory proceeding (intradocket relations) or across several regulatory proceedings (interdocket relations). Primary artifacts also include those produced by a specific regulatory bureau within the FCC, or artifacts produced by several bureaus. An intertextual perspective on policy change also has reach in that it allows intra- as well as interinstitutional analysis like that just discussed, namely, the relationship between the activities of Congress, various courts, regulatory agencies, or even corporations. Following the parallel trajectory of different institutions' policy-making actions allows observing the variety of related and intersecting secondary and tertiary actors across a number of institutional settings. In the case of the 2002 cable modem Ruling, for example, we observed the linking together of multiple dockets in one policy statement, the selectivity in how the regulatory past structures the regulatory present, and the strategic use of language; all of these steps are part and parcel of most policy processes. An intertextual perspective is also compatible with how policy scholars have described policy processes, its unique contribution being its capacity to reveal fissures in policy texts, negotiations over linguistic choices, and the constitutive dimension of writing practices that are so central to policy-making. For example, an intertextual perspective asks what types of artifacts most help “policy entrepreneurs” (Sheingate, 2003; Wagner, 1966) forge coalitions and push policy measures. It can be used to highlight the ways in which the FCC's docket genre demonstrates the “incrementalism” (Lindblom, 1979) of its regulatory process. It also asks how intertextual knowledge of prior legislation, court cases, scientific studies, or FCC rulings and orders demonstrate instances of “bounded rationality” (March & Simon, 1958), “groupthink” (Janis, 1972), or even occasions for “policy learning” (Zarkin, 2003a), where the focus is on how decision makers draw lessons, adjust their strategy, and respond to inputs about a public policy topic. An intertextual perspective also captures the extent to which policy advocacy coalitions (Sabatier & Jenkins-Smith, 1993) cite each other or similar artifacts in their regulatory filings. Mapping intertextual relations among FCC dockets over several decades provides evidence of what “punctuated equilibrium” theorists (Baumgartner & Jones, 2009) characterize as long periods of policy stagnation interspersed by bursts of change. Similarly, such intertextual mappings can be used to illuminate the endurance and also the contingencies of past policies. Such mappings even help locate where “policy streams” (Kingdon, 2011) actually emerge or possibly even where certain issues have been pushed forward, while others have been left in the background. For example, why is it that some textual definitions and signifiers become more important than others, carry through the decades, and re-appear in different primary, secondary, and tertiary artifacts while others do not? Who or what is responsible for making some signifiers more important than others? What is the determining factor for either getting pushed forward or staying in the background? An intertextual perspective also complements a “path-dependent” approach (Mahoney, 2000) in its capacity to trace sequences and patterns in regulatory proceedings over short and long periods of time. Finally, an intertextual perspective on policy change is portable: it can be applied in a variety of jurisdictional settings, both domestic and international, making it transferable to other settings for comparative research purposes. Focusing on the work of policy advocates grounds analysis in the material artifacts that facilitate the evolution of specific ideas, efforts, values, and norms. Most importantly, however, an intertextual perspective speaks to the interpretive aspects of policy change as articulated by interpretive policy analysis (IPA) scholars who advance enquiry into the types of social meanings produced by symbolic language, symbolic objects, and symbolic acts that are part of policy-making processes. As Yanow (2003, p. 11) observes Interpretive research attends to data of three broad sorts: language (spoken by actors in the situation or in written form such as in state documents or individuals' diaries); acts and interactions (including nonverbal behavior); and physical objects used in these acts or in written language (such as governmental buildings, census questionnaires, mission statements). In this view, instead of drawing purely on public opinion surveys, focus groups, cost benefit analyses, or other common evaluative and often quantitative approaches to policy study, IPA scholars privilege the role that language and discourses play in policy-making processes and debates. Future telecommunications policy scholarship might explore these interpretive dimensions, focusing particular attention on the contingent relational dynamics that characterize policy change, namely, how the writers and readers of primary, secondary, and tertiary artifacts influence policy change by influencing each other, and how policy artifacts play potentially multiple, intersecting roles in policy struggles. Acknowledgments I would like to thank the anonymous reviewers for their helpful comments and suggestions. I would also like to acknowledge the following people for their insights during the development of this article: Lance Bennett, Gabriella Coleman, Ross Collin, Marta Fuentes-Bautista, Seeta Gangadharan, Emily Hutchison, Joe Karaganis, Katherine Lemons, Alex Mochnacki, Laura Murray, Philip Oxhorn, Allison Perlman, Charlotte Ryan, Sylvia Saakes, Keith Serry, Christina Spiesel, Jonathan Sterne, and Tom Streeter. Notes 1 " The first instance was in the title of a policy memo Wu (2002) wrote on the topic. Wu (2003) expanded the memo into a law journal article titled “Network Neutrality, Broadband Discrimination,” and for reasons that are not explored in this article, the first term “stuck” with readers, perhaps in part due to alliteration. Wu also developed an ex parte filing with his mentor, Larry Lessig, in a Federal Communications Commission (FCC) regulatory proceeding (Wu & Lessig, 2003). This article considers these examples of policy advocacy (the policy memo and the ex parte filing) and legal research (the law review article) as secondary and tertiary artifacts, respectively. The notion of primary, secondary, and tertiary artifacts is explained in Figure 2. 2 " Note that definitions of information versus telecommunications services appeared in the policy record as early as 1982 via the U.S. Department of Justice Consent Decree with AT&T (United States District Court for the District of Columbia, 1982). Both definitions were later codified in the Telecommunications Act of 1996 (1996). The regulatory precursor to “information service,” however, is the FCC's 1980 definition of enhanced service: " services, offered over common carrier facilities used in interstate communications, which employ computer processing applications that act on the format, content, code, protocol or similar aspects of the subscriber's transmitted information; provide the subscriber additional, different, or restructured information; or involve subscriber interaction with stored information. Enhanced services are not regulated under Title II of the Act. (Federal Communications Commission, 1980) 3 " The idea of sedimentation is drawn from Merleau-Ponty's notion of shared linguistic worlds and acquired linguistic meanings (Flynn, 2011). 4 " By this time, in the regulatory record, protocol processing is seen as a type of enhanced (versus basic) service and as such, not subject to regulation by the FCC (Federal Communications Commission, 1986b, paras 15–40). 5 " The FCC also defines in Section C (paras 15–40) distinctions between the terms “protocol,” “protocol processing,” and “protocol conversion.” A protocol is defined as “a term of art used by data communications engineers to denote the standardized system-operating disciplines and technical parameters that subscribers and carriers must utilize and observe in order to permit the exchange of information among terminals connected to a specific communications network” (Federal Communications Commission, 1986b, paras 15–40). 6 " See paragraph 16 in FCC 86-253, which distinguishes between protocol processing and protocol conversion as follows (emphasis added): " “Protocol processing” is a generic term that denotes the use of a computer or computer-like device to process the protocol-related symbols appearing either in a subscriber's transmission or generated within the network for the purpose of intra-network data transport. Protocol processing takes place throughout the process of setting up and maintaining end-to-end communications. We consider “protocol conversion” to be a subset of “protocol processing.” Protocol conversion is the specific type of protocol processing that is employed to permit communications between terminals or networks that observe disparate protocols. In both analog and digital networks, protocols must be established and protocol processing must take place. (Federal Communications Commission, 1986b, para. 16) 7 " On the basis of a personal interview with Tim Wu on March 23, 2012, about his motivations for taking up network neutrality research and his early framing of the issue, reflecting on his early work, he noted that his analysis was technologically astute while also perhaps somewhat legally naïve given that at the time, he was not an expert in telecommunications history. Nevertheless, Wu's most recent work, The Master Switch (2010) acknowledges that the term network neutrality is not his creation alone, but has roots in the history of the breakup of AT&T. 8 " See other work for a more in-depth history of the theory and its applications (Allen, 2000; Hebel, 1989; Orr, 2003). 9 " The macrodimension features analysis of social practices that shape the circumstances, norms, and conventions that both enable and constrain mesolevel discursive practices. The textual practice, or microlevel dimension, features lexical and grammatical analysis of a specific instance of a discursive practice (Fairclough, 1992, p. 4). 10 " Recognizing that many other FCC dockets overlap and intersect with this docket, this one has been chosen for illustrative purposes. 11 " The primary artifact of interest featured in this article is the third of five artifacts in a specific FCC proceeding: GN Docket No. 00-185. Thus, within the docket itself, there are two earlier artifacts and two later artifacts on either side of the primary artifact shown in Figure 2. 12 " I am proposing that secondary activities in this adaptation of Fiske's framework are those individuals or organizations that submit letters, comments, or other communications directly to the FCC as part of a regulatory proceeding; these are referred to by the FCC as “filings.” These filings may draw on any number of previous artifacts, for example, legislation, court cases, academic research, news stories, or independent research provided by a think tank, advocacy organization, or other entity. Each artifact, whether primary, secondary, or tertiary, therefore, has its own synchronic and diachronic lineage. In this view, the distinction between secondary and tertiary has nothing to do with the type of actor producing an artifact as part of a policy debate or process; instead, it has to do with the proximity of participation, to a policymaking practice. 13 " Figure 2 indicates that these 332 filings are diachronically linked to the FCC's 2002 Declaratory Ruling and Notice of Proposed Rule-making that was issued in March 2002. That order prompted 177 responses, or filings. 14 " See Comstock and Butler (2000) for discussion of the codification of regulatory terms in the 1996 Telecommunications Act. References Allen , G . ( 2000 ). Intertextuality . London, England : Routledge . Google Scholar Google Preview OpenURL Placeholder Text WorldCat COPAC Armstrong , D. M . ( 2004 ). Memorandum: National Cable & Telecommunications Association, et al. v. BrandX Internet Services, et al., No. 04-277 and Federal Communications Commission and the United States of America v. 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TI - Excavating Historicity in the U.S. Network Neutrality Debate: An Interpretive Perspective on Policy Change
JF - Communication, Culture & Critique
DO - 10.1111/cccr.12033
DA - 2013-12-01
UR - https://www.deepdyve.com/lp/oxford-university-press/excavating-historicity-in-the-u-s-network-neutrality-debate-an-ZWI6jpY0Yu
SP - 568
VL - 6
IS - 4
DP - DeepDyve
ER -