Hit Delete Button on Outdated Data Requests, Industry Tells Commission
AT&T, Verizon, NCTA and other industry players asked the FCC to eliminate unnecessary data reporting requirements in light of changes in the communications world since the Telecommunications Act was enacted 14 years ago. The filings were in response to request for comments by the Wireline, Wireless and Media bureaus. But Free Press and other public interest groups said much of the information is critical to understanding communications markets and the FCC should exercise extreme care in considering changes.
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AT&T said it faces “comprehensive data collection requirements” imposed before the “robust competition” that the Telecom Act brought. “Numerous providers, including ILECs, CLECs, wireless providers, cable companies, and others, using varying technologies and platforms, compete vigorously to provide voice, data, and video services to businesses and consumers,” the carrier said. “While the competitive landscape has changed dramatically over the past 15 years, the regulatory framework has not kept pace with these changes, and, consequently, telecommunications services remain subject to a host of outdated regulations, including outdated data collection requirements."
Verizon and Verizon Wireless jointly recommended that the FCC discontinue several “outdated” data submission requirements. They include remaining open network architecture (ONA) and comparably efficient interconnection (CEI) requirements that date to the FCC’s Computer Inquiry, rules requiring local exchange carriers to submit detailed information on all their plants “such as descriptions of property, location information, date of placement into service, and original cost data,” international traffic reports and prepaid calling card traffic and revenue certifications.
"These items reflect antiquated reporting requirements -- in some cases applicable to only a few among many competing providers -- that are either no longer useful to consumers (if they ever were) or to the Commission in today’s competitive environment or should be changed to reflect the modern communications marketplace,” Verizon said.
The FCC “has an on-going responsibility to ensure that the obligations it places on regulated industries in this area do not impose undue burdens,” NCTA said. “Minimizing information collection burdens is not just a matter of good governance by the Commission, but is mandated as a matter of national policy through the Paperwork Reduction Act.” NCTA cited as an example of an unnecessary data requirement the Annual Report of Cable Television Systems collected through Form 325. “To be sure, the information requested on Form 325 is not identical in all respects with that gathered in other forms,” the group said. “But much of the non-duplicative information that Form 325 requests -- such as the miles of cable plant and how much of the plant is coaxial vs. fiber optic cable -- no longer appears relevant.” NCTA also cited the CableCARD status reports that the nation’s five largest cable operators are required to file every 90 days.
Free Press said the FCC should proceed with caution as it looks at eliminating reporting requirements. “Information that truly has no practical utility should not be collected. Such an action frees Bureau staff to focus on more productive data analysis, which provides additional benefits to stakeholders and the public,” the group said. “With that said, we urge the Commission to fully consider the current and/or future utility of any existing data collection.” But Free Press cited a 2008 decision to grant AT&T forbearance from a requirement to report much of the information collected through the Automated Reporting Management Information System (ARMIS). “The end result of the ARMIS forbearance proceeding was the cessation of the collection of important data with a Commission promise to collect that data in a different format,” Free Press said. “Not surprisingly, this promise has long been forgotten."
The Communications Workers of America said the FCC should preserve in particular ARMIS reports on service quality and customer satisfaction. “CWA, as well as other consumer groups, state Commissions, and state consumer advocates, rely upon ARMIS service quality data to analyze industry performance and network quality, and there is simply no substitute for the national ARMIS database that collects uniform data across states, companies, and over time,” CWA said. The group said it has used the ARMIS data to prepare filings “in numerous state and FCC proceedings."
The Minority Media and Telecommunications Council said the FCC should streamline its data requirements but at the same time improve its data collection on employment, media ownership and broadband deployment. “Commission policy should be driven and supported by relevant and complete data sets,” the council said. “The Commission’s civil rights and social justice initiatives, many of which have been pending for years, cannot move forward unless the agency changes course. The agency needs reliable, transparent data that Commission staff, other government agencies, researchers, and advocates alike can use to shape policy to ensure greater opportunity for all.”