238. The Wireless Internet Service Providers Association (WISPA) opposes the 
adoption of an
advisory opinion process "because it assumes an inherent uncertainty in the 
rules and creates a 'mother
may I' regime -essentially creating a system where a broadband provider must 
ask the Commission for
permission when making business decisions."615 According to WISPA, "[t]his 
system would increase
regulatory uncertainty and stifle broadband providers from innovating new 
technologies or business
methods. It also would be expensive for a small provider to implement, 
requiring legal and professional
expertise.

239. We find that WISPA's concerns are misguided. Because requests for advisory 
opinions
will be entirely voluntary, we disagree with the contention that their use 
would force broadband providers
to seek permission before implementing new policies or technologies and thereby 
stifle innovation.617 In
addition, we agree with other commenters that advisory opinions would provide 
more, not less, certainty
regarding the legality of proposed business practices.


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