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WASHINGTON, Aug. 9, 2022 — The Federal Communications Commission is cautioned not to unduly burden Internet Service Providers with its Congressional mandate to collect pricing and subscription rate data from Affordable Connectivity Program participants.

Under the Infrastructure, Investment and Employment Act, the FCC is required to adopt rules by November 15 to collect annual data on the prices and subscription fees of each Internet service offering from a provider participating in the broadband subsidy program that is up to $30 offers per month for low-income households (up to $75 per month in tribal areas) and a one-time $100 discount on a device.

But a number of filings warn the FCC about rules that require additional data collection efforts beyond what is permitted by law to avoid unduly burdening vendors and, according to at least one other trade group, to discourage vendors from participating in the program.

Telecom company Lumen, for example, recommended that the commission limit the scope of annual reporting to monthly prices, excluding “overly granular” requirements such as promotional rates, inventory rates or subscriber-level data, which the commission proposes to collect.

Communications companies and industry groups want to limit data collection

T-Mobile said in its filing that Congress had told the FCC to rely on broadband consumer labels due in November for pricing. The Commission asked for comments on the interpretation of the IIJA, which requires reliance on pricing information displayed on consumer labels.

Regarding subscription information, T-Mobile is asking the Commission to review data collection by the Universal Service Administrative Company – which administers expensive broadband programs for the Universal Service Fund – to “avoid largely redundant collection that would impose additional burdens.” . all parties.

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“The IIJA leaves the Commission no discretion to collect additional pricing information, and the law does not require the collection of data on other service plan and network characteristics,” such as speed and latency and data allowances, the filing reads.

“Collecting this additional data would create additional burdens and is unnecessary,” the filing added.

Similar restrictions were also proposed by Telecom Starry Inc., which was pushing for privacy by collecting data at a higher level (e.g. the state) and working with information collected in other transparency efforts such as the consumer identifiers.

Industry association IMCOMPAS, which represents the Internet and competitive communications networks, told the FCC in a statement that data collection should be limited to the state level to protect consumer privacy and providers’ proprietary information; Streamline other data collection, including consumer labels; and provide guidance on how vendors can better understand data collection rules.

This position is echoed by the Wireless Internet Service Providers Association, which said data collection must be simple and should not go into detail, which goes beyond what the IIJA requires. The trade group, which represents small vendors, said such data collection beyond what is required by law could burden companies with small teams.

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The data included, WISPA said, should be an annual summary of items, including broadband plans subscribed to by ACP customers, number of subscribers to each plan, and prices less special tariffs, taxes, rebates or price breakdowns for bundled services. Any additional incriminating collection could result in providers leaving the program, it added.

Industry bodies US Telecom and NCTA – Internet and Television Association, were similarly pushing for a simple annual report that would track the bare-bones monthly price of each broadband service offering and the number of subscribers. The Competitive Carriers Association and the Cellular Telecommunications and Internet Association also recommended a limited data collection approach.

ACA Connects, a trade group that represents small and medium-sized independent operators, said the FCC should direct providers to report the number of ACP households “applying their benefit to each speed tier, along with the standard price of each tier in a state.” -by -state basis” — rather than the FCC’s proposed continuous collection of subscriber-level data through the National Lifeline Accountability Database, she said, adding the commission should consider the time it will take to complete given the limited nature of smaller providers have resources.

Others are pushing for more subscriber-level data

The cities of New York and Seattle indicated in their submissions that the FCC should collect subscriber-level information to assess different service adoption rates for different plans over time — and publish categories based on price, plan, and performance by zip code. It added that it is not looking for information about the households themselves and said it was not a privacy issue, as others have pointed out.

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Similarly, the Connecticut Office of State Broadband said the commission should go beyond the IIJA requirements by mandating information including plan compliance and whether a device will be offered.

For the National Digital Inclusion Alliance, data collection on the ACP should include data beyond that contained in consumer labels and should include other items such as installation, equipment, service, miscellaneous, data and usage charges, and state and local taxes.

In a joint filing, nonprofit media group Common Sense and internet advocacy group Public Knowledge recommended collecting data needed to monitor the ACP, including promotional pricing, taxes, overcharges, and device and equipment costs. That way, they say, the FCC can get a better picture of how much is being spent on Internet access after the subsidy is applied. They also want the Commission to collect information on whether the subsidy is being used to improve or discount current service and how customers become aware of the program.

The Commission is currently trying to attract more Americans to the program, which has over 13 million households enrolled. That number, the commission said last week, should be much higher. As such, it ordered the development of an outreach program to market the grant.

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