NCTA/ACA Defend Cable Customer Email Petition Against Condition Calls
Some of the conditions suggested for a joint NCTA/American Cable Association FCC petition for approval to email customers such information as instructions and services offered would make electronic notification more burdensome and actually undermine the benefits sought in the petition…
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and should be rejected, NCTA/ACA said in a joint filing Friday in docket 16-126. The petition drew a variety of suggested conditions (see 1606130028). "Most problematic" is an opt-in consent requirement before cable operators could send notices electronically, since cable operators already have that and the point of the petition was for Media Bureau approval to not have opt-in consent, the two said. Seeking and obtaining individual opt-in consent from customers runs contrary to the paperwork-saving benefits of the petition, they said, adding the FCC hasn't required opt-in consent for other electronic notifications to customers, such as annual backup power notices. They said they agree with a collection of local governments that the emailed version include a route for opting out. But NCTA/ACA said the bureau needn't specify that route "so long as the option chosen is readily available and not difficult to exercise." They said local governments' suggestion cable operators be banned from selling or marketing with those customer email addresses would be superfluous: "There is no basis -- and no history of email abuse -- to support these conjectural concerns." They also said use of customer email addresses already is regulated. NCTA/ACA said some suggested clarifications are unobjectionable -- for example, a requirement that customers can withdraw their consent at any time, as suggested by NATOA and Minnesota Association of Community Telecommunications Administrators; or the local governments' suggestion for what would constitute a "verified email address."