Failing to Pass the Straight-Face Test

Sept 12, AT&T filed comments with the Office of Management and Budget on the Federal Communications Commission’s woefully deficient analysis of the burdens associated with the so-called enhanced transparency requirements adopted in the 2015 Open Internet Order (OIO). The Commission’s analysis evinces a complete disregard for its responsibilities under the Paperwork Reduction Act. The FCC has not specifically identified the things Internet service providers (ISPs) must do to comply with the new transparency requirements; it has not separately estimated the burden of each requirement; it has not explained the benefits that would justify these requirements; and its lowball estimate of the overall costs is absurd on its face. The FCC’s PRA analysis, which took the Commission more than a year to complete, does not pass the straight-face test. We hope OMB will reject it.