FCC Broadband Labels: Unveiling the New Mandates and Reporting Requirements - ETI
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January 26, 2024

FCC Broadband Labels: Unveiling the New Mandates and Reporting Requirements

The following transcript has been edited for length and readability. Listen to the entire discussion here on The Broadband Bunch. The Broadband Bunch is sponsored by ETI Software and  VETRO FiberMap.

Joe Coldebella:

This episode of The Broadband Bunch is sponsored by ETI Software and VETRO FiberMap.

Broadband Labels and Reporting Requirements Unveiled

Brad Hine:

Hello everyone in broadband land. Welcome to another episode of The Broadband Bunch. I’m your host, Brad Hine. And once again, I am bringing you stories, stats, and samples from the world of broadband.

Recently, the FCC announced that service providers will be required to display broadband labels on their websites and at point-of-sale storefronts. These labels are identical in form to FDA nutrition labels that we all know. The reason is cost accuracy and ongoing bandwidth performance are key to consumers. Most believe this is a reaction to the lengthy contracts where line-item billing info is a challenge to understand and to make absolutely sure the service being delivered is always consistent.

This is not the only reporting required by the FCC this year. The Affordable Connectivity Program, or ACP is an FCC benefit and credit program that helps ensure that all households can afford the broadband they need for work, school, healthcare, and more. There is some overlap with ACP in broadband label reporting. I will mention the first report for ACP is due November 9th, 2023, which is this week. Joining me today to discuss the impacts of these requirements is a journeyman in the telecom broadband industry, a colleague, and a frequent contributor to the broadband bunch, Mr. Jeff Boozer. Jeff, welcome to the bunch.

Jeff Boozer:

Hey, thanks for having me, Brad. It’s good to be back.

Navigating the Extensive Reporting Landscape

Brad Hine:

Absolutely. We are stepping into a new realm in terms of reporting and service tracking for all these providers with all the money that’s about to be injected into the market.

Jeff Boozer:

Yeah, that’s very true. And it is extensive reporting. One of the things that I think is important for people who are listening to understand is the implication of these rules is that no one’s really going to be immune to it. Without getting into the weeds in a lot of detail, the fact of the matter is that if you use any public internet for access for your customers, anyone’s network who is public, it is going to require you to participate in this reporting. And I’m not sure everyone’s totally aware of that, at this point.

Brad Hine:

No one is immune, and so who specifically is required for this information? Is this broken up into categories in terms of service providers, subscription lines, and things like that? How does that work?

Unveiling the FCC’s Reporting Requirements

Jeff Boozer:

Yeah, it’s officially targeted to carriers, obviously, who are participating in programs like the ACP that are getting those subsidies to help their subscribers. That’s the direct target if you will. Those carriers are required to report monthly to the FCC about bandwidth speeds, averages, minimums, and things like that. Most everyone has seen the actual reporting requirements.

But as I was saying, the surprising part of that is the trickle-down effect that I mentioned before. As you begin to use the services of those carriers who are direct targets, then you become an indirect target and are required to do that. That’s not exactly clear sometimes until you start digging into the regulations. So the real impact here is if you offer broadband services at all, you need to prepare for the fact that you’re going to have to submit these reports.

Brad Hine:

Gotcha. This sounds like the next evolution of the FCC 477 report that we’ve all come to know and love over the years.

Jeff Boozer:

Well, yeah. Consider that as an introductory shot. It’s just a start. And with as much public money in particular that is in here, you’re looking a little bit like a return to the days of old RUS kind of funding in the original wire-line telephone world. Some of the things that they lived with for years. Not that it’s going to be quite as extensive, I don’t think. But it feels like what it used to be a little bit.

FCC Label Requirements and ACP Reporting

Brad Hine:

Gotcha. Well, before I jump into the direct impact on these business units and the providers, I was doing a little research before our conversation on the FCC site. It looks like the label requirements will start on April 10th, 2024. The providers with 100,000 sublines or more must comply by April 10th, but providers with less than 100,000 lines have until October 10th, so the fall. Whereas the ACP, as I mentioned in my intro, is due this week.

Jeff Boozer:

Uh oh, hope you have it ready.

Brad Hine:

So what could be some of the challenges here? I know it sounds like we’re not just talking about simple services now being on a website, it sounds like all product packages need this label. They need to be on a website, and they need to be fully communicated before that service can go live. Is all that factual?

Deciphering FCC Label Requirements

Jeff Boozer:

Yeah. Let’s start with labels because that’s one you have to do some considerations. The labels, you were right on the dates, April 10th of ’24 for the larger carriers and October 10th for the smaller carriers. If you are a carrier, you need to stop and consider this very carefully, because labels are going to impact your business.

Let’s start out with what’s required. Every broadband product has to have a label, and that label has some very specific rules around it that drive how you set products up. I won’t try to go into every single one of those here because it’s quite extensive, but you basically need to understand that now product labels are specific to geographies and other kinds of categorizations that demand that you have multiple product codes and labels for what you may consider to be the same product across your service area. That’s going to be one of the big impacts because every single product, as defined by the FCC, will end up with a unique code in the FCC database. For those of you, back to the old wire-line analogy. Remember USOCs? Welcome them back. Here they are in a different form.

Without making this a really long conversation just about labels, pay very close attention and start as soon as you can looking at what it’s going to take to comply because I promise you it’s probably a little more extensive than we were all expecting it to be.

The Imperative for Automation in Compliance

Brad Hine:

Well, it sounds like discussions that we’ve seen in the industry for years now about data silos within business units now the experience that I saw with the FCC 477 gathering is that a lot of it was manual because there were data silos that couldn’t be broken down. So that’s going to be key for providers to start to automate.

Jeff Boozer:

You read my mind. That’s exactly where I was going. So yeah, the problem you’ve got to look at here is exactly that. The traditional data silos we have in the industry today that have existed for years, this information is going to touch your marketing systems, where your addresses and things like that are saved. It’s going to touch your subscriber systems and billing system and for sure it’s going to require network data to be compiled out of your monitoring and systems assurance systems. All of this must be collected, combined, and then analyzed across these product categories as well. So it is more than a simple reporting exercise. This is a data analytics exercise.

 The FCC’s Impact on Product Catalog Management

Brad Hine:

Gotcha. This is a ton of data that we’re talking about at this point, too. So how does this affect a product management team? We know, not to get too technical, but I’ll delve in slightly. All of the product pricing, as you know with your OSS and BSS history, will live in one place. And it has to be accessed. What does this do for a product management team at a service provider? Did we just add more jobs to their department? It’s about to explode.

Jeff Boozer:

Their job security just went right off the charts. The FCC reporting is literally driving product catalog management to be a critical factor in the business now. So if you just take what we were saying a couple of minutes ago, and you look at a traditional product catalog the average carrier will have somewhere between 75 to 80 versions of a product in there. And those products apply across their service areas in most cases. They may have it categorized by a market or something. Well, now, if you look at FCC requirements, you can expect that product catalog’s going to go somewhere between five to 10 times the size it is right now just in unique products.

The FCC’s Impact on Continuous Management

Brad Hine:

Wow.

Jeff Boozer:

And every product must be managed through a complete lifecycle. So the other big impact of it is this. If you decide that you’re going to change a product, even something as simple as changing the price on a product, maybe you’re changing a feature on a product, et cetera, you don’t get to change anymore, you get to add another one to that. As long as that product is active in the field and grandfathered in on somebody else, you can’t touch it because of the labeling requirements. So now not only is product management an exercise of meeting the market and making sure you’re providing competitively differentiated products wherever now it’s a federal recording and reporting requirement that makes it even more critical to the business that someone manages it closely and accurately.

Brad Hine:

Wow. Our experience with the pandemic made it obvious that we all have to be connected. Now as we’re trying to close this gap, it sounds like some of the reporting requirements are going to revolve around confirming that you delivered the service consistently that you said you were going to deliver. I don’t know how frequent that will be, but it sounds like now the consumer has a little more power in this.

Consumer Transparency Empowered by FCC

Jeff Boozer:

Well, the consumer has, I’m reluctant to say, they have power directly, but they have transparency that can give them leverage for certain.

Brad Hine:

Gotcha. That is a much better word.

Jeff Boozer:

The transparency is driven by the FCC requirements, obviously. And you’re right, you must report on average speeds attained, maximum speeds possible, what you promise versus what you deliver, and minimum speeds. There is an awful lot of performance data that will be required in order to satisfy the FCC’s reporting requirements.

So data that you might not even be currently capturing and reporting on in any particular case is now going to be a requirement for external reporting so while most carriers do have internal performance statistics that they look at to measure network and predict and forecast capacity requirements and all of the other things you traditionally do behind the scenes at the NOC, it’s out front and public now. So if that data is not available or is not as clean, accurate, and compiled as you might need it to be, it’s time to start working on it.

Data Analysts in the FCC Compliance Journey

Brad Hine:

Wow, great comment. Great comment. Well, we all know, as kids, those nutrition labels that we used to read on our cereal boxes in the morning before we would go to school. So we’re looking forward to the same type of experience. But how would a broadband service provider start the process, perhaps, of trying to reign this in and get a handle on it, Jeff?

Jeff Boozer:

Well, let’s start with maybe a concept that we’ve been using for a while that most people would be familiar with. In the past years, we evolved a thing called a data warehouse in a lot of carriers where we were taking data from disparate sources and putting it into a single database, if you will, or a single structure, so that you could begin to look at performance across different areas or across the business, but especially in terms of a lot of network kind of information. That’s an interesting way to start looking at what you need to do going forward.

A lot of companies now are into data analytics. They even have positions on staff called data analysts. If you don’t, you should probably start looking at that concept because they are going to be key to your operations going forward. And then that data analyst is going to need a common source of data across all the applications that the business uses. There are tools, there are common database models out there that a carrier can come in and adopt.

Streamlining Compliance through Integration and Tools

In many cases, you’re going to have to attack the integration or access to that data yourself. So that’s the need for the data analyst, to be able to start pulling some of those data pieces together. And that database that you use to collect all of this needs to have a really powerful reporting tool that can sit on top of it that will allow you to do that.

Now, I’m sure as we get into this and more and more carriers raise their hands and ask for help from their various strategic vendors, you’ll find solutions emerge for that. And there will be companies that will come along and be able to automate this process for you, or at least provide you a toolkit whereby you might be able to do the automation yourself. Ultimately, you’re going to have to automate these.

They will be so time-consuming. As the data grows and expands, the sheer volume is going to make it a requirement that you automate these processes. And that needs to be taken into account as you start to even build some data to do the first few of these, however, you may be accomplishing it. But automation has to arrive, and it needs to arrive as soon as possible. And like I said, I know there are some out there that are working on some solutions for this.

Navigating FCC Mandates and the Road Ahead

Brad Hine:

Right. Time is of the essence for sure. Jeff, thanks again for coming to The Broadband Bunch and sharing your opinions with us about some of these new mandates and requirements by the FCC. I want to invite you back soon, maybe before April of next year to report on what progress you’re seeing in the industry in terms of this. But I want to encourage all our listeners still to check out our website, broadbandbunch.com for weekly episodes, iTunes, Spotify, and SoundCloud. Jeff, thanks again. Any parting bits of information for our listeners today?

Jeff Boozer:

I just want to quote somebody who gave a great quote, “Time is of the essence.” Thanks again, Brad. It’s always fun, love talking to you. Thanks, everybody for joining in.

Brad Hine:

Thank you, Jeff. Have a great day, everyone. Bye-Bye.