STATEMENT OF COMMISSIONER ROBERT M. McDOWELL Re: Modernizing the FCC Form 477 Data Program, WC Docket No. 11-10; Development of Nationwide Broadband Data to Evaluate Reasonable and Timely Deployment of Advanced Services to All Americans, Improvement of Wireless Broadband Subscribership Data, and Development of Data on Interconnected Voice over Internet Protocol (VoIP) Subscribership; WC Docket No. 07-38; Service Quality, Customer Satisfaction, Infrastructure and Operating Data Gathering, WC Docket No. 08-190; Review of Wireline Competition Bureau Data Practices, WC Docket No. 10-132. Re: Review Of Wireline Competition Bureau Data Practices, WC Docket No. 10-132; Computer III Further Remand Proceedings: Bell Operating Company Provision of Enhanced Services; 1998 Biennial Regulatory Review – Review of Computer III and ONA Safeguards and Requirements, CC Docket Nos. 95-20, 98-10. Many thanks to Mary Beth Richards and Greg Elin for your presentation. Your dedicated work in conducting a comprehensive review of the Commission's data collection obligations is appreciated. I wholeheartedly support reducing the Commission's regulatory burdens wherever possible, including eliminating certain reporting requirements. I am encouraged to hear that your team has already targeted 20 collections to discontinue soon. In that spirit, I support the Notice of Proposed Rulemaking which proposes to eliminate the Commission's remaining Computer III requirements. Due to various reforms over the years, collection of this information may no longer be necessary, and it does not appear that the Commission relies on this data in its decision making process. In short, collection of this data is likely antiquated and burdensome. I commend the Chairman for taking this step to clear unnecessary regulatory underbrush. In addition, I support the Notice of Proposed Rulemaking which seeks to modernize the FCC Form 477 Data Program. Given that the Form 477 process has not been reformed in more than 10 years, initiating this proceeding will hopefully result in a more efficient and effective program. It is important for the FCC to obtain appropriate and relevant data to help us make informed decisions, and this rulemaking will open the dialogue on this topic. However, we must ensure that we have adequate legal authority to require the collection of the information discussed in this notice. As such, I was encouraged that the Chairman agreed to ask about our legal authority throughout this rulemaking. I am hesitant, however, about the section of the notice which discusses whether the FCC should collect broadband pricing information. Although such efforts may have the best of intentions, I am concerned that if the FCC ultimately decides that it should collect broadband pricing information, the process could lay the foundation for the FCC to engage in rate regulation of broadband Internet services in the future. I hope that doesn’t happen. I will be interested to learn more about others’ perspectives during the comment cycle. In sum, I do support our effort to modernize this process but we must be wary that we aren't taking one step forward and two steps back by reducing data collection requirements in some areas, but then imposing new and unnecessary burdens in other areas. I thank Sharon Gillett and her team for their long hours working on these two notices, and I look forward to reviewing the record and working with my colleagues and stakeholders on these proceedings.