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American Cable Calls On FCC To Lessen Paperwork Burdens On Small And Medium-Sized ISPs

Agency Underestimating Time, Manpower Requirements of Enhanced Transparency Rule

PITTSBURGH, July 24, 2015 - The American Cable Association called on the Federal Communications Commission to lessen the paperwork burden on small and medium-sized ISPs from the new broadband transparency requirements.

"The FCC needs to recognize that key aspects of the just adopted enhanced transparency rules impose real burdens on small and medium-sized ISPs, many of whom have no in-house legal or regulatory personnel and will need to hire outside firms to navigate a complex regulatory regime. Further, many of these new requirements have little, if any, benefit for customers of ACA members. ACA calls on the FCC to follow the requirements of the Paperwork Reduction Act (PRA) and reduce burdens for these ISPs," American Cable President and CEO Matthew M. Polka said.

American Cable expressed its views in comments filed July 20 with the FCC as part of the agency's PRA-mandated review of the enhanced transparency rule. The enhanced transparency rule imposes a series of new obligations, including a requirement that broadband ISPs disclose detailed information related to pricing, privacy, performance characteristics, and network management practices.

In its comments, ACA said that under the PRA, the FCC is obligated to minimize paperwork burdens, especially on small businesses. ACA said the FCC's recent estimates about the time and cost required to comply with the enhancements to the transparency rules (including clarifications to existing requirements and the adoption of new and more granular disclosure requirements regarding commercial terms, performance, and network practices) significantly understate the costs that small and medium-sized ISPs will incur to collect and disclose additional information about network practices.

As a result, ACA called on the FCC to take the following steps as part of its PRA review to alleviate burdens imposed by the network practice and notification requirements:  

  • Amend the network practice requirement to require that providers only disclose the trigger that will activate use of the practice for a particular type of traffic and not the information about the purpose of the practice and the effect on a user's experience;
  • For medium-sized providers (those with more than 100,000 but less than 400,000 customers), provide guidance stating these providers have sufficient flexibility to establish appropriately tailored customer notification procedures and to determine the best way to respond to customer inquiries; and
  • For smaller providers (those with fewer than 100,000 customers), continue the exemption adopted in the 2015 Open Internet Order.
About the American Cable Association: Based in Pittsburgh, the American Cable Association is a trade organization representing about 850 smaller and medium-sized, independent cable companies who provide broadband services for nearly 7 million cable subscribers primarily located in rural and smaller suburban markets across America.  Through active participation in the regulatory and legislative process in Washington, D.C., ACA's members work together to advance the interests of their customers and ensure the future competitiveness and viability of their business.  For more information, visit http://www.americancable.org/

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