Wireless Carriers, Others Fight New FCC Reporting Requirements
Wireless carriers, cable companies, satellite operators and rural local exchange carriers asked the FCC not to impose Automated Reporting Management Information System reporting requirements on them, as part of an FCC push to gather more data on broadband deployment. But some state commissions and public interest group Free Press said the ARMIS requirements provide useful data and should be expanded to all companies that offer broadband service.
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The industry may face a tough fight to avoid new mandates. In September, the FCC cut back significantly on reporting requirements for the major wireline carriers, but also launched a rulemaking exploring whether to ask for new types of data to be filed by all broadband providers. The FCC’s two Democrats, Michael Copps and Jonathan Adelstein, to be in the majority next year, stressed the importance of the data submitted under ARMIS and said the requirements should be updated instead of scrapped.
The CTIA said the ARMIS requirements had a specific purpose when crafted -- “to place a check on the behavior of large, incumbent local exchange carriers at the inception of the price cap regulation system in the early 1990s.” But today they are “antiquated, unnecessary and ineffectual.”
Mike Altschul, CTIA general counsel, said in an interview that the ARMIS data would be of little use to consumers. “A lot of this information is available to the public outside of FCC reporting,” he said. “It’s available through consumer reports and JD Power a lot faster and in a lot friendlier format than an official government report is ever going to be.” Imposing wireline reporting requirements on wireless makes little sense, Altschul added. A CTIA filing said that “wireless service quality is uniquely impacted by factors such as the propagation characteristics of the spectrum being utilized, network capacity, weather, topography, foliage, the number of customers using the cell or cell section, and whether a customer is in-building or in- car.”
AT&T, one of several big carriers that got forbearance from ARMIS requirements earlier this year, said there’s no longer a need for collection of service quality, customer satisfaction, infrastructure and operating data: “Market forces assure that service providers will maintain service quality and continue to invest in new and improved services to retain existing customers and attract new ones.”
Verizon and Verizon Wireless said reporting rules should apply equally to all broadband providers. “But the Commission must evaluate whether there is a need for this ARMIS data from anyone. There is no such need,” the companies said: “ARMIS infrastructure and service quality data are outdated and meaningless, and the Commission already collects sufficient data to serve its broadband and public safety objectives.”
Rural rate-of-return carriers also raised concerns. “The imposition of new requirements on rural LECs would impede the efforts of these carriers to continue deploying and upgrading broadband services in the high-cost areas they serve,” said the Western Telecommunications Alliance and the Organization for the Promotion and Advancement of Small Telecommunications Companies in a joint filing.
The satellite industry is subject to reporting requirements and shouldn’t be required to provide more data, both Hughes Network Services and the Satellite Industry Association said in separate comments. Requiring satellite providers to report ARMIS data “would place a heavy burden on satellite broadband providers that is not offset by the limited insights that the Commission would gain from the information collected,” Hughes said.
The FCC established the ARMIS reporting requirement to ensure that wireline carriers provided a sufficient level of customer service and invested in upgrades to their networks. Satellite broadband providers “regularly spend millions of dollars to build, replace and service their satellite and earth station infrastructure that provide nationwide service,” Hughes said. The SIA suggested that a better way to measure customer satisfaction is by monitoring complaint data.
But Free Press disagreed with industry comments that ARMIS reporting is no longer relevant. The industry has seen many changes since the requirements were imposed, the group said. “What has not changed however is the simple fact that today’s essential communications technology -- broadband -- is offered in a marketplace that lacks adequate competition,” it said. “Thus the need for the Commission to gather data regarding infrastructure and service quality has not changed.”
Free Press said the FCC should require carriers to submit three measures that would help it assess the quality of broadband service being offered nationally: The total capacity dedicated to residential service, the total amount of bandwidth supplied through that capacity and the total potential bandwidth demand. “The Commission should also require the reporting of the total amount of spectrum that exists within the network, the total sheath kilometers of wire, the total fiber kilometers deployed (lit and dark), and the average distance from customer premise to fiber,” the group said. “This information will provide the Commission ability to track investments being made to increase overall network capacity.”
The Michigan Public Service Commission said some of the data collected under ARMIS remains critical for state policymakers and all broadband providers should have to file data. ARMIS service quality reports and infrastructure reports “have been important tools available to state commissions to be able to access and analyze industry data that is otherwise unavailable to them,” the commission said.