The FCC should drop any proposal to require...

the initial comment cycle (CD Jan 22 p2). “The proposed metric will not serve consumers,” CTIA said (http://bit.ly/MANDrW). “Rather, the metric would send consumers the incorrect message that site outage statistics are a reasonable proxy for the reliability of individual providers’ networks and the quality of their resiliency practices. Indeed, the proposed [Disaster Information Reporting System] DIRS-related metric is statistically meaningless.” The requirement won’t make the public safer, CTIA said. It could have “the negative unintended consequences of creating incentives to favor individual cell site restoration over service restoration, and it may create disincentives for carriers to engage in the type of voluntary, mutual assistance that has successfully characterized restoration efforts on an ongoing basis.” PCIA offered similar advice: “The record demonstrates that additional regulation is unnecessary because robust competition among wireless providers drives investment in network resiliency and [they] plan extensively for rapid restoration of service” (http://bit.ly/MAO7hz). But Consumers Union and Public Knowledge said in joint replies that after reading the record they still believe the data filing mandate would be good for consumers. “We remain convinced that public disclosure of wireless network performance and recovery during and after major weather events and other disasters, using the proposed metric, would provide consumers with useful information,” PK and CU said (http://bit.ly/1nOlI2Y). “We remain convinced that it would also help promote important improvements in network strength and resiliency."