Dear Chairman Powell and Fellow FCC Commissioners:
On behalf of the 350,000 members of the National Taxpayers Union (NTU), I write to offer our views on a pending issue before the FCC. Specifically, we urge you to deny the National Association of State Utility Consumers Advocates' (NASUCA) petition for declaratory ruling prohibiting "monthly line-item charges, surcharges or other fees on [wireless] customers' bills unless such charges have been expressly mandated by a regulatory agency" (CG Docket No. 04-208).
The National Taxpayers Union continues to find it ironic that so-called "consumer advocates" are unable or unwilling to see why most of their policy positions are actually anti-consumer in nature. NTU further finds it ironic that these same advocates seek to place regulatory constraints on wireless service providers, even though the regulation-heavy environment these groups prefer might have repressed the emergence of such services to begin with. We can only speculate as to what future technological developments will be inhibited or delayed as a result of current regulations. Thus, beyond being detrimental to the consumers of today, over-reaching regulation is detrimental to consumers of tomorrow.
It is therefore NTU's position that any government imposed restrictions on wireless service providers' ability to delineate for consumers the cost of providing such services--be they explicit or implicit--are unwarranted restrictions and not in the best interest of consumers. Besides wreaking havoc on a wireless service provider's ability to offer mutually beneficial package plans, consumers will be left in the dark as to what costs they are ultimately being forced to bear by their elected officials. Consumers benefit from transparency, not misguided attempts to "dumb-down" their bills.
Recent data released by the FCC on the level of wireless-related customer complaints indicates that NASUCA is proposing a solution to a problem that does not exist. According to the FCC's own data, wireless billing-related complaints in the first and second quarters of 2004 amounted to 0.0022 percent--or 22 per million. If the IRS had such a record we at NTU could probably cut back to a four-day workweek.
NASUCA and other like-minded groups should stick to providing consumers with information on how to read their bills and shop for service. If they really want to help consumers, they should set ideology aside and work instead to roll back burdensome taxes and regulations on wireless service providers.
Sincerely,
Tad DeHaven
Economic Policy Analyst