CFA Seeks Separate Proceedings on Title II Forbearance

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The Consumer Federation of America is advising the Federal Communications Commission to look more closely before it leaps to a decision on which of the Title II common carrier regulations not to apply to Internet service providers (ISPs).

CFA Director of Research Mark Cooper called FCC General Counsel Jonathan Sallet to advise the FCC to provide independent notice and comment proceedings on how to apply more than a dozen sections of the Telecommunications Act to ISPs if they are regulated as telecommunications service providers. While Cooper said the FCC could arguably forbear from the rate regulation authority under Title II, the FCC needs to study whether to forbear from regulations involving extension of lines; telecommunications services for hearing-impaired and speech-impaired individuals; universal service; disability access; liability for acts and omissions; customer information privacy; blocking/screening offensive material; regulation of pole attachments; barriers to entry; interconnection, and more.


CFA Seeks Separate Proceedings on Title II Forbearance