Providers Oppose More Broadband Reporting Requirements

Additional data collection “will not yield timely accurate data,” while customer surveys “will inappropriately supplant the existing market for consumer rankings and quality surveys with one bearing the seal of the federal government,” CTIA said in comments. The FCC should wait to make new reporting requirements until it gauges the effectiveness of the March order in getting better data, said Verizon and Time Warner Cable separately.

Carriers said new reporting requirements could prove costly. AT&T usually supports FCC broadband data gathering efforts, but the agency’s latest proposals “represent a significant departure from the Commission’s longstanding pledge to collect only ‘essential’ data and to do so in a minimally burdensome fashion,” the carrier said. The FCC should ensure new reporting requirements don’t force rural LECs to “significantly alter their normal business practices or incur substantial costs,” the Organization for the Promotion and Advancement of Small Telecommunication Companies and the Western Telecommunications Alliance said in joint comments. Costly requirements could hurt small LECs’ ability to buildout broadband, they said. RLEC financial consultant Telcom Consulting Associates agreed, saying the FCC shouldn’t require more granular data from RLECs “without proper reimbursement and protection of the data provided.”

Providers also raised confidentiality red flags, urging the FCC to refrain from releasing sensitive competitive data publicly. But the FCC should dismiss the argument, said Consumers Union, Consumer Federation of America, Free Press and Public Knowledge in joint comments: “Much of the information we request… is already available to consumers, just not in a manner that enables informative comparative analysis.” Also, “any new information collected that is not currently available to the public would produce significant public benefits through its release, far outweighing any claimed competitive concerns.”

Carriers already provide sufficient data on voice telephone connections, several carriers said. Voice data is “competitively sensitive” and “not relevant” to broadband deployment, ITTA said. VoIP data might reveal information on broadband, but it’s unclear how data on switch-based voice connections would help, it said. If the FCC requires more detailed data, it should require interconnected VoIP providers to supply comparable information, OPASTCO and WTA said.

It’s not the FCC’s job to collect price data, ITTA said, and that would run counter to the FCC’s “classification of broadband as an information service outside the purview of price regulation.” The NCTA said the commission shouldn’t collect data on how much broadband costs because consumers already can get that information on their own from ISPs and third parties. If the FCC tracked prices without accounting for discounts, that could skew the figures, said the group. “Moreover, there is an inevitable, and inevitably long, time lag between companies reporting their data and the Commission publishing it. Time-lagged reports would be meaningless as soon as they are released.”

If the FCC collects price data, it should only require providers to report “the monthly prices the provider charges for stand-alone broadband service in each of the speed tiers used for Form 477 reporting,” not including promotional or service-bundling discounts, Qwest said. Even then the data would be useless, AT&T said, because e-mail, firewall, parental controls and other features vary from provider to provider.

Carriers don’t -- and shouldn’t -- gather data on actual delivered speed, ITTA said. The data is useless because Internet speed depends not only on deployed infrastructure, but the “activities of other users” using the network simultaneously, it said. Wireless broadband delivered speed data would also be meaningless, said Sprint Nextel, because speed is affected by number of customers using a cell site, distance from the cell site, terrain and foliage. Communications Workers of America urged the FCC to work with CWA and others to establish a voluntary registry for consumers to report delivered speeds. Broadband providers don’t have “incentive to report this information accurately,” but a Web-based test could get the data, CWA said.

The FCC shouldn’t head up broadband customer surveys, several said. Data are “available from other governmental agencies, state-level public-private partnerships, and private sector research groups that already conduct surveys,” Verizon said. Surveying consumers would be a “deviation from the intended uses of the Commission’s resources,” ITTA said. Qwest is OK with surveys, it said, as long as it doesn’t impose extra costs on carriers and results acknowledge that “the survey pool would likely skew to those with complaints.” People with positive experiences may not feel as compelled to participate as people with broadband problems, the carrier said.