ACA restated its position with the FCC in reply comments filed June 16 in connection with the agency's proposals to educate consumers on their broadband needs.
Rather than imposing the burden on broadband providers, ACA is recommending that the FCC develop a "need for speed" consumer guide similar to the USDA's "food plate" (formerly the "food pyramid"). That would be a simple government-developed guide that informs consumers of how best to meet their broadband Internet service needs. ACA is also advocating that the FCC can best preserve broadband Internet service provider flexibility and minimize economic burdens by limiting the obligation of providers to making a consensus "need for speed" guide available on their websites.
ACA noted that not burdening broadband providers with creation of the speed guide largely tracks with recommendations supported by an array of stakeholders, including Time Warner Cable, CTIA - the Wireless Association, the Organization for the Promotion and Advancement of Small Telecommunications Companies (OPASTCO), the National Telecommunications Cooperative Association (NTCA), and the Western Telecommunications Alliance (WTA).
ACA does not believe the FCC should require broadband providers to develop and maintain their own individualized speed guides for consumers. Such an approach would be well beyond most broadband providers, particularly smaller ones, both in terms of manpower and costs. Instead, ACA encourages the FCC to develop -- in collaboration with industry and other stakeholders -- the speed guide because it would satisfy the FCC's goal of assisting consumers in making informed broadband purchase decisions in a efficient and cost-effective manner.
ACA stressed that in developing its speed guide, the FCC must minimize economic and administrative burdens on broadband providers, particularly smaller providers. In term of consumer notice, ACA asked the FCC not to require broadband providers to do anything more than display the broadband speed guide on their websites or provide links to an FCC-developed guide, or both.
"The record solidly supports ACA's recommendation that the FCC keep any "need for speed" guide obligations to a bare minimum. Posting the broadband speed guide on a company's website will make the information available to every Internet user and potential broadband service purchaser. This practice should suffice to achieve the FCC's goal of helping consumers understand what level of broadband service will best meet their needs while minimizing additional economic burdens on providers," Polka said.
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