Do we really need Net Neutrality?

Responding to a recent publication by Comcast, they assert an open network policy. Their claim is, at best, highly dubious.

As clearly indicated in their PeeringDB entry, Comcast does not

offer peering, paid or otherwise, on the shared fabric public switches at any IX

What's an IX? It's a regional Internet Exchange; they enable ISPs to directly exchange settlement-free traffic, without requiring that each provider maintain dozens of expensive physical links. Thereby cost-effectively keeping your internet activity local, while making your connections to internet services faster and more reliable. It's a tried-and-true technique which thousands of ISPs have used to improve performance and reliability, for decades.

If Comcast's "open" internet approach was true, then why does their network peering policy, undoubtedly impair network performance, introduce unnecessary chokepoints, and manufacture congestion?

Comcast, TODAY

For instance, today, my NetFlix traffic is carried all the way through Portland Oregon, and then Seattle, and then Denver, and then Dallas TX, before being released from Comcast's network. Comcast-NoIX-Netflix

Comcast, If They Were Truly Open

If Comcast had an open peering policy, my traffic would be passed onto Netflix's network over a local 20Gbps public peering interconnect, without ever leaving Portland, Oregon. Comcast-IX-Netflix

This issue is not unique to Portland Oregon; Comcast's peering policy affects interconnects across the entire United States.

At least in Portland, Oregon, a single 10Gbps port on the regional peering fabric would cost Comcast a mere $400/month ($300/month for the 10Gbps port & $100 for the cross-connect). This seems like such a small price to pay, for so many benefits to be gained.

Why does Comcast refuse to leverage an absurdly inexpensive, tried-and-true technique, which thousands of ISPs have used to improve performance and reliability for decades? In the FCC's own words, how is Comcast's approach commercially reasonable? Ultimately, how is Comcast's business policy reflective of an Open Internet approach?