Cable and Telecom Tell FCC They Inform Broadband Consumers

In response to a Federal Communications Commission request for comment on consumer transparency and measurement of fixed services, the cable and telephone industries let the FCC know they are transparent -- and that measuring actual speed is a tricky thing.

The National Cable and Telecommunications Association says cable operators provide a great deal of information about their broadband services to consumers at every stage of the purchasing process. With respect to information regarding the "actual" speed of broadband services, we continue to encourage the Commission to consult with Internet engineering experts to develop measures that would be meaningful to consumers and not unduly burdensome to providers, rather than adopting new rules based on potentially flawed data or unwarranted assumptions.

The United States Telecom Association says consumer disclosure and measurement of fixed broadband services are enormously complex areas that elude simple, one size fits all, answers. Fixed broadband services are constantly evolving and service choices are expanding with each innovation. Moreover, consumers' uses of their fixed broadband services are also evolving and vary considerably. Consumers who use the Internet simply for web surfing and e-mail may need a different type of broadband service from consumers who use the Internet for gaming and real time entertainment. As new applications come online, usage patterns change. In the face of these variations, defining and providing transparency is very difficult. Measurement presents similarly difficulties because the type of measurement most relevant to meet one consumer's needs may be different from the type of measurement that will provide the most meaningful information for a different consumer. coming to thoughtful and practical answers will, USTelecom believes, require more than the on-going workshop and notice and comment processes already underway at the Commission. Further, given the variety of approaches to resolving the issues of measurement and transparency, it is vital to build consensus among the stakeholders. Therefore, to complement and improve the outcome of the Commission's ongoing processes, USTelecom believes that industry, public interest groups and other interested stakeholders should join together to articulate best practices with respect to disclosure and to create a technology neutral and understandable measurement methodology.