The Consumer Federation of America (CFA) applauds the Commission for initiating this proceeding to write an Open Internet Order2 under the Section 706 authority recently outlined in the ruling of the United States Court of Appeals For The District Of Columbia Circuit. We believe this is exactly where the effort to build a Broadband Network Compact should start, so much so that we devote this initial early comment to a detailed analysis of why this proceeding is so important as the first step in the process.