The FCC is getting plenty of pushback from ISPs on its estimates of new transparency information collection requirements in the new net neutrality rules that took effect June 12, with wireless carriers suggesting its estimates and justifications are so off base as to need a reboot.
In its comments to the FCC, CTIA: The Wireless Association, pulled no punches, calling the FCC's estimate of an additional 4.5 hours per year absurd and calling the FCC's estimates of the additional paperwork burdens "indefensibly inaccurate."
As part of the new rules, the FCC expanded ISP obligations to inform customers about network management practices and their impact on customer's broadband service, part of FCC chairman Tom Wheeler's focus on informing subs when their promised broadband speeds or service could be altered by such practices.
Given the potential millions of dollars in fines for noncompliance, "it is absurd for the Commission to suggest that these providers will spend only an additional $200.75 or 4.5 hours per year to ensure compliance with the 'enhanced' transparency requirements," CTIA said.
The Office of Management and Budget reviews any new reporting requirements in new regulations per the Paperwork Reduction Act (PRA), which mandates that an agency take steps to minimize additional paperwork.
CTIA said the current transparency rule—adopted in 2010—is already "extremely burdensome," that the expanded transparency requirements are of little practical utility, are ambiguous and not clearly understandable, and that the FCC still needs OMB approvals for some parts of the new notifications that it has not sought.
"The Commission’s Open Internet PRA effort is so flawed and riddled with unsustainable assumptions that the Commission should issue a new notice that provides the 'specific, objectively supported estimate of burden' that the PRA requires," CTIA said.
