AT&T Seeks FCC Clarifications of Broadband Transparency Duties

a rule change when its order said broadband providers must disclose actual "relevant information" to consumers at the point of sale, and not simply provide a Web link to such disclosures, as the agency had said they could do under 2011 guidance. If the FCC changed its rule, "it would impose a new collection requirement and enormous new burdens on the industry that could not be justified under the Paperwork Reduction Act (PRA), and which plainly was not part of the Commission’s May 20, 2015 Public Notice," AT&T said, adding that if the FCC intended a change, it must publish a new public notice seeking comment. AT&T also said the commission should clarify that a requirement for collecting new information on mobile broadband performance wouldn't apply "until the planned Measuring Broadband America program for mobile services is in place and available as a safe harbor, to avoid forcing mobile providers to incur substantial costs implementing measures that may become moot or unnecessary." AT&T said mobile providers measure performance in different ways, so their current data wouldn't provide customers useful information. Finally, AT&T said the FCC should clarify that broadband providers will have at least a year, after the Office of Management and Budget approves any new FCC information-collection rules, "to implement the many system changes, and new methods and procedures, necessary to comply." In recent comments, AT&T and others said the FCC was dramatically underestimating the cost of industry compliance with its new rules (see 1507220048).