Common Cause Joins Public Knowledge in Urging the FCC To Provide Transparency on Educational and Outreach Rules During Technology Transitions  

On May 31, 2018, Common Cause joined Public Knowledge in a letter urging the FCC to provide transparency as to why the agency’s education and outreach technology transition rules from 2016 never went into effect. The rules require telecommunications carriers to provide education and outreach to their customers when they are seeking to replace their legacy phone network with a new service. The rules are specifically tailored to ensure the most vulnerable communities including low-income, the elderly, and people with disabilities have the information they need to understand what to expect when their legacy voice service is discontinued. The FCC now seeks to eliminate these rules with the rationale that they never went into effect and are burdensome. Common Cause strongly objects to the elimination of the education and outreach rules and urges the Commission to fully disclose why they never went into effect.

The following can be attributed to Yosef Getachew, Director of Media and Democracy Program:

“The FCC’s technology transitions process is a critical piece of closing the digital divide, bringing modern communications infrastructure to all Americans, and ensuring that telecommunications carriers are accountable for the quality of service they provide. The education and outreach rules were designed to ensure that all Americans, particularly those most vulnerable, understand what to expect when their legacy voice service is discontinued.

“Unfortunately, the FCC now seeks to eliminate its education and outreach requirements under the premise that they never went into effect and are unduly burdensome. The only information the FCC provides as to why the rules were not implemented is that the Office of Management and Budget (OMB) never approved them. However, the FCC fails to disclose what factors lead to OMB suspending its review and what role if any the Commission played in this. Stakeholders who would be adversely affected by the elimination of these rules have a right to know why these rules were never approved and should have an opportunity to respond as part of the Commission’s rulemaking proceeding.

“The Commission also fails to provide any evidence that the education and outreach rules are burdensome. Rather than conduct any cost-benefit analysis, the FCC relies on statements made from monopoly telecommunications companies who offer no evidence to support their assertions that the education rules are burdensome. Without enforceable rules, these companies are unlikely to provide robust education and outreach that consumers need to understand their change in service.

“In seeking to eliminate these rules, the Commission threatens the nation’s most vulnerable populations who still rely on the traditional phone network for service. Common Cause strongly objects to the elimination of the education and outreach rules and urges the Commission to fully disclose why they never went into effect.”

To read the letter, click here.