STATEMENT OF
COMMISSIONER MIGNON L. CLYBURN
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.
Good policy must be informed by complete, accurate, and relevant information.  We should be 
mindful, however, that the collection of data for accurate analysis occupies the resources of both industry 
and the Commission, and that ultimately, consumers and taxpayers are the ones who pay.  Accordingly, it 
is appropriate for the FCC to periodically review the need for the information it requests.  Where 
currently collected data is no longer relevant for the benefit of Congress, the Commission, or consumers, 
we should begin proceedings to explore the elimination of that information, as we do today, with respect 
to the CEI/ONA data.  
Of course, to the extent that data from industry is required so that we can fulfill our statutory 
obligations, then it is important that we ensure that the information we obtain is sufficient for us to do so.  
As such, it is important to periodically assess whether the data we are collecting, relays the information 
we need to make good policy choices and to issue reports required by statute.  With respect to the 
information we collect on the Form 477, which we use as our primary tool for analyzing the status of 
local telephone and broadband networks and services, I support the Notice’s consideration of 
modifications to the types of data reported on the Form.  As the Notice describes, our various duties to 
promote policies that ensure universal service, public safety, a competitive communications marketplace, 
and the reasonable and timely deployment of broadband networks, require that we have the data necessary 
to make informed decisions, and issue knowledgeable reports, just as Congress intended.  
I believe it is appropriate for us to revisit the type of data we seek on the Form 477, given that 
both a GAO Report and the National Broadband Plan found that the data was insufficient, and limits our 
ability to fulfill certain of our policymaking and reporting duties. Certainly, we must balance the need for 
information with the burden that data collection may have on industry.  The Notice recognizes this careful 
balance, by seeking guidance on the possible use and limitations of publicly available or third-party 
commercial data, to avoid such burdens on industry, including small businesses.  
I am pleased that we are exploring the use of additional broadband data, such as pricing 
information, so that we can better assess affordable and comparable prices.  As we consider explicitly 
supporting broadband networks and service in our USF/ICC Reform NPRM adopted today, it is important 
that we have the information necessary to determine whether rates in rural areas are comparable to rates 
in urban areas, so that we can assess whether we have met the goals of Section 254 for ensuring universal 
service.  Furthermore, the Broadband Data Improvement Act, requires that we compare pricing for 
broadband service with other countries; thus, the collection of pricing information may be necessary to 
fulfill that obligation.
Finally, I am pleased that we are undertaking a significant effort to allow the public to access the 
data we collect, as well as our analysis of that information, through our website.  It is important that as we 
are informed, we use every tool at our disposal to inform the public.  
Many thanks are due to Mary Beth, Greg and the other data experts, for your work on our Data 
Innovation Initiative, as well as to the Wireline Competition Bureau for your work on the Form 477 and 
CEI/ONA Notices.