FCC Broadband Data Requirements Insufficient, NASUCA Says
Efforts to gather broadband deployment data are falling short, the National Association of State Utility Consumer Advocates (NASUCA) told the FCC, urging the commission to seek more detailed data. Inadequate data can spawn bad policy, the group said. Consumers Union, Consumer Federation of America and Free Press agreed on the need for reform, with the FCC’s ZIP code-based approach coming in for heavy fire. Commenters took shots at Form 477, the commission’s main tool for data collection. Filings came as part of a broad FCC rulemaking also examining net neutrality requirements (CD June 18 p2).
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“Better information will enable federal and state policy makers to design and to implement programs to promote broadband availability,” NASUCA said: “There are costs and burdens associated with enhanced data collection… the benefits of adequate broadband deployment data far outweigh the accompanying costs.”
Poor data mean a flawed snapshot of broadband deployment failing to show that rural areas are not alone in enduring a lack of deployment, NASUCA said. “One reason for the erroneous assumption that only rural areas lack broadband deployment is the excessive aggregation of data whereby only one subscriber in a zip code is interpreted as showing full broadband deployment,” the group said.
According to NASUCA, the FCC should: seek more granular geographic data; require customer counts in each area served; calculate broadband availability; capitalize on state efforts to document deployment gaps; require separate reporting for residential and business services; collect pricing data that reflects non-introductory and non- promotional prices; require wireless broadband reporting based on subscription to a data plan, not merely purchase of a broadband-capable handset.
The consumer groups said in a filing that commission ZIP code-based measurement of subscribers means nothing and offers little insight on true broadband deployment. FCC measurement “vastly overstates” industry competition, the groups said. “The Commission’s ability to monitor the marketplace for the reasonable and timely universal deployment of advanced services is only as good as the data it collects,” the groups said: “And it is in this effort that the Commission has failed.”
The Calif. Public Utilities Commission (CPUC) said it has had its own woes collecting data from service providers. That means the FCC has an important role to play, the CPUC said: “The FCC has jurisdiction over broadband providers and plays a valuable role in ensuring that, on a nationwide basis, granular data about key aspects of broadband services are consistently developed, collected, and maintained.”
But CTIA warned FCC that the FCC could sow confusion by mandating filing of more data on wireless broadband offerings. It is impossible to shoehorn subscribers into one of a handful of categories, CTIA said. Forced use of categories “not only overlooks the benefits of month-to-month and metered Internet use plans, but also mischaracterizes wireless broadband technology and may likely result in double and even triple counting of wireless subscribers who routinely utilize services from multiple categories, and thus negate the Commission’s goals in this proceeding,” CTIA said.
Sprint Nextel also urged caution. Asking for subscriber data within ZIP codes makes sense, but “collecting information about customers who occasionally download entertainment features would require enormous resources to produce and would provide little marginal value,” the carrier said.
AT&T said the FCC should recall that Congress was seeking to encourage broadband deployment, not record keeping, when it sent data collection requirements. “The Commission’s own data collected through mid-year 2006 reveals that both broadband deployment and subscribership are robust,” AT&T said: “High-speed lines have grown from approximately 26 million in December 2003 to more than 64 million as of June 2006, while advanced services lines have increased from approximately 20 million to more than 50 million.”