Data Quality Filings: Bad FCC Data Created Bad
- "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.
- 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.
"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."
- Teletruth files FOIA over FCC Audits of Bell Continuing Property
- 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
- 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
- 2002 updatedComplaint filed with New York, New Jersey and Massachusetts
commissions: Ignored/still pending in New York and Massachusetts,
rejected in New Jersey.
- Complaint to the SEC
- Teletruth Memher Dan Berninger filed a petition with the FCC to
open up the audits;
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:
- FCC Line Charge Data Quality Act and Truth in Billling Challenge:
- Re: Request for Correction of Information: Petition to Investigate
and Remove the FCC Line Charge, Pursuant to the Federal Data Quality
"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 FCCs 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 FCCs data and analysis
fails the Federal Data Quality Acts 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 FCCs Truth-in-Billing Guidelines.
- "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 countrys 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
- "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 FCCs 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 FCCs 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 Reviews
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:
- "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 TeleTruths
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.
- 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.
"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.
- 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.
- 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.
- Report "AT&T and MCI (Verizon) Are Harvesting Customers"
- FCC's Data Quality Act Guidelines:
- Cartoon: FCC's Bad Math: Why is this Guy Smiling? http://www.newnetworks.com/fccsbadmath.htm
- Other Teletruth DQA Report and other Links:
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
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.
- In 2008 we filed a Regulatory Flexibility Act challenge as well
as a Data Quality Act complaint (still undecided), pertaining to WC
Docket No. 08-190, WC Docket No. 07-139, WC Docket No. 07-204, WC
Docket No. 07-273, WC Docket No. 07-21)
- FULLCOMMENTS AND CASE STUDY: http://www.teletruth.org/docs/TeletruthRFA.pdf
- CASE STUDY: How Regulations Designed to Help Small Business Competitors
Failed to Work and Harmed Broadband, Competition, Customers, Innovation,
and the Economy. Teletruth Requests New Proposed Rulemaking Actions
the FCC Should Take to Fix Future Problems.