Data Quality Filings: Bad FCC
Data Created Bad Phone Policies.
1994:
- "THE FCC'S DATA ON PHONE COMPANY PHONE RATES,
FINANCIALS, AND OTHER DATA ARE SERIOUALY FLAWED AND IN
NEED OF MAJOR REVISION." Original Filing: February,
3rd, 1994,Updated Complaint April 21, 1994. In 1994, New
Networks Institute filed a complaint against the FCC's
data. New Networks Institute, at the behest of former
Vice President Gore's office met with the FCC.
- http://www.teletruth.org/docs/UpdatecomplaintFCC1994.doc
1999:
- New Baby Bell Expose Refutes FCC Advanced Network
Report and Calls for an Investigation of "Info-Scandal".,
3/17/99. In 1999, New Networks Institute published "The
Unauthorized Bio of the Baby Bells", which outlined how
the phone companies had failed to deploy fiber optic
services as promised and how the FCC's data was a
'white-washing' of the fact.
- http://www.newnetworks.com/alonefccrefute4.html
"As we will demonstrate, the FCC's Report is a
white-washing, attempting to show that the Telecom Act
worked and has delivered on its promises to give
Americans new services. Unfortunately, the Report is
filled with numerous serious flaws. For example, the
report lacks concrete evidence to support their
claims."
Commissioner Tristani writes:
"I am especially concerned about the lack of hard
evidence when it comes to our obligation to determine
that advanced telecommunications services are being
deployed, and are available, to all Americans."
2003
- Teletruth files FOIA over FCC Audits of Bell
Continuing Property Records.
- http://www.newnetworks.com/fccfoiabellrecords.htm
- Teletruth, a national customer alliance, and a board
member of the FCC Consumer Advisory Committee, requests
under the Freedom of Information Act that the entire,
complete Continuing Property Records for all of the Bell
companies be made immediately available to ourselves, as
well as any other party wishing to view these books.
Cooked books are not protected by any proprietariness
because of the potential and real harms to the entire US
phone and broadband customer and competitor base.
- OUTCOME: 2007: (Associated Press also filed a
FOIA on the same topic.)ASSOCIATED PRESS ON REQUESTS FOR
INSPECTION OF RECORDS. Denied the Applications for
Review. Action by: the Commission. Adopted: 03/16/2007 by
MO&O. (FCC No. 07-25). OGC
- http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-25A1.doc
- 2002 updatedComplaint filed with New York, New Jersey
and Massachusetts commissions: Ignored/still pending in
New York and Massachusetts, rejected in New Jersey.
- http://www.newnetworks.com/fccauditcomplaintny.html
- Complaint to the SEC
- http://www.teletruth.org/docs/SECLetter2.pdf
- Teletruth Memher Dan Berninger filed a petition with
the FCC to open up the audits;
- http://www.danielberninger.com/documents/122302petition.pdf
Data Quality Act
Complaints:
New Networks Institute *(and Teletruth) were the first to
file specific complaints under the "Data Quality Act".
Teletruth has its own dedicated pages at the FCC:
2004
- FCC Line Charge Data Quality Act and Truth in
Billling Challenge:
- http://www.teletruth.org/RemoveFCCLineCharge.html
- Re: Request for Correction of Information: Petition
to Investigate and Remove the FCC Line Charge, Pursuant
to the Federal Data Quality Act
- http://www.fcc.gov/omd/dataquality/requests2004.html
"As we will demonstrate, the data that has been used
in the calculations for the FCC Line Charge, including
the phone company supplied data, the models presented to
justify the charge, and the FCC’s unjustified
inclination to accept such data uncritically from such
interested parties in meetings not open to the public are
by their very nature the definition of regulatory capture
by industry interests. We therefore are left with no
other option but to conclude that both the data and the
decisions that have resulted from the use of such data
are biased in the extreme. The public deserves a more
open process and a regulatory body more respectful of
their duties and responsibilities under the Data Quality
Act. TeleTruth maintains that only through a more open
and fairprocess can such charges be investigated and
justified to consumers. In short, the FCC’s data and
analysis fails the Federal Data Quality Act’s basic
tenents."
- Truth-In-Billing Petition Against the “FCC
Subscriber Line Charge”. Teletruth Requests an
Immediate Investigation into Various Truth-in-Billing
Violations of the Term and Line-Item Charge “FCC
Line Charge” as Well as the Creation of a New
Proposed Rulemaking to Fix the FCC’s
Truth-in-Billing Guidelines.
- http://www.teletruth.org/docs/FCCLineChargeTIB.pdf
- "Over the last decade, the FCC has repeatedly brought
up the issue that phone bills are unreadable and that
something should be done about it. In March of 2000, the
FCC set up new guidelines and rules about the
country’s phone bills known as
“Truth-In-Billing”. The guidelines include
basic principles about the information to be supplied to
customers.And yet, phone bill information, as well as all
accompanying information has major errors or
omissions.
- "The FCC Line Charge is mislabeled and deceptive. The
common belief is that it funds the FCC, which is
wrong.FCC RULE:” …accompanied by a brief,
clear, non-misleading, plain language description of the
service or services rendered;"
- Re: Request for Correction of Information:Petition to
Investigate and Correct All Advanced Network Broadband
Reports and Analyses, Pursuant to the Federal Data
Quality Act
- http://www.teletruth.org/docs/TeletruthNIA706Dataqualityact.pdf
- "Since 1998, the FCC has been required under Section
706 of the Telecommunications Act of 1996 to investigate
the status of broadband (advanced services) and whether
it is being deployed in a “reasonable and
timely” manner.2 Also, Section 706 was designed to
encourage the roll out of broadband through various forms
of regulation (or forbearance) and promote competition.3
"With the recent release of the FCC’s 4th report
on September 9th, 2004, it is now clear that the FCC has
simply whitewashed the facts, leaving out key data points
throughout the entire process — and has delivered to
Congress and the American public a distorted picture of
broadband deployment, and has harmed the entire economy
through its lack of diligence to present major issues.
For example, the report never demonstrates that customers
in most states have already paid for fiber-based
broadband network deployments they never received.
Another series of facts totally missing is the role of
the Internet Service Provider (ISP) provider and
competitive Data-CLEC in the history of the Internet and
broadband deployments — or the harm the FCC’s
own policies have had on putting thousands of these
companies out of business, thus impacting broadband
deployments.This rewrite of the data has had severe
consequences to the entire deployment of broadband, as
well as the economy."
- RE: Data Quality Act Challenge as Per the Triennial
Review’s Initial Regulatory Flexibility Act
Analysis.1
Request for the FCC to do a Full Update of Its
Information Pertaining to the Size of the Internet
Service Provider Markets:
- http://www.teletruth.org/docs/TeletruthNIAISPnumbersDataQualityAct.pdf
- "it is 2004, two years since our original Triennial
comments, and yet we find the FCC is still quoting the
same bad data about the ISP markets from 1997 — now
8 years old!
This challenge under Federal Data Quality Act is based
on TeleTruth’s conclusions that seriously flawed
data has led to unduly selective and biased statistical
analysis which has been presented to Congress,
regulators, and the public. It has distorted ALL public
policies in the United States toward broadband deployment
and competition as well as harmed the entire financial
health of the economy.
- FCC RESPONSE IN THE TRIENNIAL REVIEW.
- http://www.teletruth.org/docs/TriennailFCC0336A1Teletruth.pdf
2005
- 38 Million "Broadband Users" in the US? America Leads
the Globe in "Broadband Connections"? Teletruth Files
Against FCC's Data — Tell the Truth About Broadband!
Get Rid of “Garbage Pail Statistics”. Speed
Matters.
http://www.fcc.gov/omd/dataquality/requests2005.html
"Teletruth today filed a Data Quality Act Complaint
against the FCC's statistics, claiming that the FCC is
politically driven to inflate the number of broadband
connections in the United States, as well as presenting a
distorted picture of broadband in the US. Point 1: The
FCC should redo its recent broadband release and retract
the FCC Chairman's statements on broadband because the
FCC's methodology gives an inflated picture of
“broadband"
- The "Missoula Intercarrier Compensation" Is a
Truth-In-Advertising, Data Quality Act Violation. There
is No Mention of the FCC Line Charge Increases in the
Press Release.
- http://www.teletruth.org/docs/IntercarriercompTeletruthDQAcomplaint.doc
- Teletruth contends that the FCC's press release and
discussions on this topic lacks objectivity and the
omission of essential data leads the Intercarrier
Compensation presentation to be biased, unreliable,
inaccurate, and not transparent documentation.
2007
- Full Complaint:Teletruth today filed a formal "Data
Quality Act" challenge against the FCC's data on phone
rates, statistics and other related data, claiming that
the information products are seriously flawed and in need
of immediate revision. Teletruth claims that the data
fails in being objective, lacks quality and is not
reliable, lacks utility, and is not reproducible, thus in
violation of the Act. http://www.teletruth.org/docs/Dataqualityactharvesting.doc
- Report "AT&T and MCI (Verizon) Are Harvesting
Customers"
http://www.teletruth.org/docs/ATTMCIharvest.doc
- FCC's Data Quality Act Guidelines:
http://www.fcc.gov/omd/dataquality/complaint/
- Cartoon: FCC's Bad Math: Why is this Guy
Smiling? http://www.newnetworks.com/fccsbadmath.htm
- Other Teletruth DQA Report and other Links:
http://www.newnetworks.com/dataqualityactchallenge2.htm.
Specifically referenced in the complaint are FCC
reports: "Trends in Telephone Service", February 2007,
"Reference Book of Rates, Price Indices, and Household
Expenditures for Telephone Service", testimony presented
by Chairman Martin, press releases, and every other
document that uses the FCC phone rate information.
This Data Quality Act complaint is based on
Teletruth's report "AT&T and MCI (Verizon) Are
Harvesting Customers" and outlines how bad data has
created bad and harmful policies. As we will show,
Teletruth has found that over 1/3 of US households have
been harmed because the data is so inaccurate that it has
covered over major rate increases and other harms to
mostly low volume users and especially seniors.
The flawed data are also being used as part of new
proposed plans, such as the "Missoula Intercarrier
Compensation" plan that will raise the FCC Line Charge
(on every local bill) to (a cap of) $10.00, increase
Universal Service and add new fees. http://www.teletruth.org/FCCMissoulaletter.htm
And it is clear that this same bad data was used in
the FCC's AT&T-SBC-BellSouth and Verizon-MCI mergers
to the detriment of the public interest.
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