The evolution of lobbying coalitionsCo-filing behavior in FCC docket 01-92 on Inter-carrier CompensationWork in progress, 9/30/2009Pierre de Vries, Economic Policy Research CenterUniversity of Washington, Seattle

AcknowledgementsBill Cline and ElhadjiSy (FCC), for providing the underlying public data in a usable formMarc Smith and Tony Capone, for developing and supporting the NodeXL visualization toolJonathan Banks and Anthony Jones (USTelecom), for help in extracting the “et al.” data, and Risa Pavia (UW) for help in creating the fix list

ConclusionsGraph-theory clusters representreal-world alliancesTracking the evolution of clusters can reveal shifts in alliancesImproving ECFS interfaces and data quality will improve public knowledge of lobbying activity

Co-filing AnalysisMetadata from FCC ECFS database, FCC docket 01-92, April 2001 –December 2008 2,9015 filings, 756 unique filersSubsidiaries and “doing business as” entities are usually grouped togethere.g. Cable and Wireless plc, Cable & Wireless, Cable and Wireless USA, Cable & Wireless North America. But for some large players, kept parts separate, e.g. Verizon and Verizon Wireless; AT&T and AT&T WirelessSub-set of FCC docket 01-92 where two or more entities file togetherEntities that only filed on their own are not shownUsed either metadata given as multiple entity names, or extracted entities from filed documents where “et al.” or “filed on behalf of” given in metadataTrade associations and coalitions have not been unpacked into their constituentsSometimes distorts data, e.g. AT&T is represented both on its own account and hidden within the “Missoula Plan Supporters” nodeCoalitions unpacked: Oregon Rural LECs, Five State Regulatory Commissions, Coalition for Rational Universal Service and Intercarrier ReformCompanyname changes on acquisition/merger not accounted for: Frontier Communications Corporation was formerly known as Citizens Communications CorporationDon’t distinguish between “old” and “new” AT&T, or Verizon before and after MCI merge

Filing intensity varies over timeFNPRM issued 11/5/08Responses (10/25/2006) to FCC PN (issued 7/25/06) on Missoula Plan (filed 6/24/06) FNPRM comments (5/23/05)FNPRM reply comments (10/20/05)NPRM comments (8/21/01)Reply comments (11/05/01)Responses (10/18/02) to T-Mo et al Petition for Declaratory Ruling (filed 9/6/02)

Links between 01-92 and other docketsPetition of AT&T for interim declaratory ruling and limited waivers pleading cycle establishedIMPLEMENTATION OF THE LOCAL COMPETITION PROVISIONS IN THE TELECOMMUNICATIONS ACT OF 1996In the Matter of Establishing Just and Reasonable Rates for Local Exchange CarriersFEDERAL-STATE JOINT BOARD ON UNIVERSAL SERVICEIn the Matter of Universal Service Contribution Methodology Federal-State Joint Board on Universal Service 1998 Biennial Regulatory ReviewACCESS CHARGE REFORMIn the Matter of Inter-Carrier Compensation for ISP-Bound TrafficIn the Matter of Federal -State Joint Board on Universal Service High-Cost Universal Service SupportNumbering Resource OptimizationIn the Matter of IP-Enabled ServicesIn the Matter of Lifeline and Link-UpRequest Petition for Declaratory Ruling that AT&T's Phone-to-Phone IP Telephony Services are Exempt from Access ChargesAll linked dockets 2001-2008, filtered: Sub-graphs level 1.5 centered on 01-92 (i.e. all nodes linked to 01-92, and links between them)edge weight >40 (dockets on either side of the edge were noted together on a filing more than 40 times)Edge width and color both indicate edge weight: wider/pinker means more joint mentions

Companies typically either always file solo, or always jointly498 entities always filed alone, e.g. BellSouth, NARUC152 entities always filed with someone else, e.g. Broadview, Maine PUC25 entities filed with others in 40%-60% of cases, e.g. tw telecom, Pac-WestSolo filers excluded from co-filing analysis

Links between FilersIf the names of A and filer B both appear on a particular filing…… they are treated as being linkedFiled on Date 1Filed on Date 1ABABABThe more often they file together…… the darker the line connecting them (think of the lines being stacked one on another)Filed on Date 3Filed on Date 2ABABABABAB

Different co-filing occurrences…… lead to a network structureFiled on Date 1Filed on Date 3ABABBABCCSo far the graphs looked at all filings simultaneously. Looking at a sequence of dates shows different links at different times:Filed on Date 2Date 1Date 3Date 2ABABABABABCCCCDeriving a Network Structure

The area of the blob is proportional to the total number of filings made over the whole period (solo or joint)Additional node attributes (1): SizeAT&T filed many times (big blob), whereas PointOne filed seldom (small blob). However, one can see that they’re roughly equally linked to other filers. That means that AT&T filed more often on its own.

The more pink a blob is, the more important the filer is in the network.The color represents the “eigenvector centrality”. A filer with high eigenvector centrality is connected to many filers who are themselves connected to many others. This “centrality metric” goes beyond simply counting the number of connections a filer has; connections to filers who are themselves highly connected confer more influence that connections to less well connected filers.Google’s PageRank algorithm is a variant of this metric; a page is considered important if many other important pages link to it.Additional node attributes (2): ColorNew Global Telecom and Verizon have the same influence in this graph (same color), even though Verizon filed more often (bigger blob)GCI, CompTel, and NCTA filed the same number of times (same size), but CompTel is the more influential (pinker), and GCI less (bluer)Even though CTIA filed often (big blob) it’s not very influential/connected in this network (blue color)

New Global Telecom and Verizon have the same influence in this graph (same color), even though Verizon filed more often (bigger blob)

GCI, CompTel, and NCTA filed the same number of times (same size), but CompTel is the more influential (pinker), and GCI less (bluer)

Even though CTIA filed often (big blob) it’s not very influential/connected in this network (blue color)

All co-filings 2001-2008 on inter-carrier comp docket 01-29

Nodes are laid out (by hand) to respect clusteringClusters calculated using Clauset Newman Moore (2004) algorithm (Wakita & Tsurumi 2007 optimization) to find community structure, gathering vertices into groups such that there is a higher density of connections within groups than between them

A Time SeriesUnderlying data set has day-by-day granularity; these snapshots are integrated over much longer periods

2001-2002CLEC reply comments to NPRMT-Mobile et al petition for declaratory ruling

2003-2004CLECs’ “Cost-Based Intercarrier Compensation Coalition” (CBICC)Intercarrier Compensation Forum, filed ICF Plan 5 Oct 2004“Indep. Wireless Carriers”: T-Mobile, W Wireless, Dobson“CMRS Petitioners”: T-Mobile, W Wireless, Nextel

2005 – summer 2006CLECsMajor CLECs – FNPRM comments & repliesCLECs, some eventually merging e.g. Lightship, CTC, Conversent; and Xspedius & tw telecomRural LECs and their associations

Fall 2006 – end 2007Missoula Plan AlliesMissoula Plan Opponents:Mix of CLECs, ILECs and Indep. WirelessOregon Rural LECs, supporting Missoula Plan

Jan – July 2008The calm before the storm

Aug/Sep 2008ILEC/IXC coalition: Ex parte advocating federalizing VOIP, uniform comp rate for all trafficCLECs opposing Verizon’s September 12 proposal, incl. uniform rate

Oct 2008Five State regulatory commissions objecting to “eleventh hour filings”Small ILECs trying to slow down processBroadening CLEC coalition opposing change towards flat rateMid-size rural LECs opposing flat rate comp, supporting status quoOPASTCO/WTA Plan

Nov/Dec 2008“Coalition for Rational Universal Service and Intercarrier Reform” – urban & rural CLECsOpposition to AT&T/IXC “self-help” from small LEC and conf-call playersRural cellular – note they’re closer to the CLECs than the RLECs

Summary of Coalition PatternsOpponents are connected: ILECs, CLECs, and cellularRural LECs and their associations keep to themselves

Top 20 Impact Depends on Chosen MetricCLECs not only band together, but also file a lot, and often.NTCA carries the water for RLECs* Filers that appear in three or more columns are color coded

ObservationsGraph clusters seem to correspond to real-world interestsA large number of filings form one large connected graph (the blob in the center)It’s connected in aggregate over the whole time series: shifting alliancesIn the course of the proceeding, one can find a link between opposing parties e.g. a proponent of the “Missoula Plan” like AT&T is linked to an opponent like XO via both of them co-filing with the CTIA at different dates (“Six Degrees of Kevin Bacon”)There are many parties that only co-file once or twiceMost of them are pairsThere are a few large groups of co-filers that show up only once in the record, and aren’t seen before or afterFrequent Filers are usually different from Cross-ConnectorsFrequent filers like AT&T, CTIA and NTCA don’t often file in coalitionConnectors that bridge alliances (e.g. Hypercube, iBasis) don’t file all that oftenSome fall in both groups, e.g. XO and Cavalier

Value of the approachInsiders can use graphs to identify:detailed trends at a glancepotential collaborators or defectors, e.g. by looking for coalition members who are bridges between groups, or peripheralOutsiders can grasp the overall structure of a proceeding without having to read the entire recordNews organizations can use:cluster evolution to show changes in coalitionsnetwork structure to guide understanding of search results

Implications for FCCPoor quality of information input by filers impedes transparencyEndless misspellings of company namesNot all entities involved in a filing are listedFilers make mistakes (e.g. mistyping docket number) but can’t remove mistakes; they simply file againRequire more information in metadataRequire all entities names to appear in the Filed on Behalf Of field, i.e. “et al.” not allowedDistinguish between ex parte letters and meetingsUse standard web techniques to facilitate data input and retrievalRequire log-in with company ID when submitting data to ECFSRequire filer name to be registered; subsequently metadata can only be chosen from pre-registered information, not added de novoOffer drop-downs and auto-complete to add co-filersProvide web interfaces for downloading data in bulk, and as daily feedsImprove systems for correcting errorsAllow filers to remove incorrect data (only filer can remove what was filed)Penalize errors, e.g. by naming and shamingInvest in cleaning up old data: requires public/private effort?

CaveatsGraph depends on metadata entered into ECFS by filers, which can be unreliablemisspellings (e.g. ATT for AT&T) inaccuracy (e.g. a filing attributed to AT&T was actually on behalf of a number of companies, and so is not counted as a co-filing)ambiguity (e.g. there are many companies whose name includes “Citizens”, and they all seem to be different)

Some Bad Data ExamplesBellSouth:BellSouth CorationBellSouth CorpmBellSouth Corps BellSouth D.C. BellSouth TELECOMMUN BellSouth TELECOMMUNIC BellSouth TELECOMMUNICA BellSouth TELECOMMUNICAT BellSouth TELECOMMUNICATI BellSouth Telecommunication BellSouth Cellular CORPOR Misspellings of “Communications”:ComminicationCommnicationsCommunictionsCommuicationsCommuincationsCommuncationsCOMMUNIATIONS CommunicaitionsCOMMUNICAITONS CommunicatiionsCommunicatinsCommunicationasCommunicationsnCOMMUNICCATIONS CommunictionsCommunocationsComunicationsCoommunicationsCummunicationsCalifornia PUC:CALIFORNIA PUBLIC UTILIL CALIFORNIA PUBLIC UTILIT CALIFORNIA PUBLIC UTILITE California Public Utilites Commission CALIFORNIA PUBLIC UTILITI California Public Utilities CALIFORNIA PUBLIC UTILITIES COMMISSION California Public Utilities Commission - 99-204 California Public Utilities Commission and People of the State of California California Public Utiltiies Commission Calilfornia Public Utilities Commission Commissioners Lynch and Wood, California Public Utilities Commission People for the State of California and Ca. Public Utilities Commission People for the State of California and Cal. Public Utilities Commission People for the State of California and California Public Utilities CommissionPeople of the State of California & Public Utilities Commission People of the State of California and Cal. Public Utilities Commission People of the State of California and California People of the State of California and California Public Utilities Commission People of the State of California and Public Utilities Commission People of the State of California and the Cal Public Utilities CommissoinPeople of the State of California and the California Public Utilities Commission Public Utilities Commission of the State of California State of California and the California Public Utilities Commission State of California Public Utilities Commission The People of the State of California and by proxy for CPUC The People of the State of California by proxy for CPUC

Caveat (ctd): Coalitions are UnderstatedAnalysis puts a lower bound on connectivitySome connections are not revealed through co-filing; entities may be linked, e.g. through participation in a trade association, but not file together explicitlyCo-filing is undercounted since we rely on the metadata entered into ECFS. Sometimes just one company name given, even though there multiple companies involved, or a list of company names may not include all filers. (This data can be obtained from the underlying document, but at the price of significantly more effort.)This analysis deals with only one docket; companies may co-file more frequently on other dockets

Conclusions (restated)Graph-theory clusters representreal-world alliancesTracking the evolution of clusters can reveal shifts in alliancesImproving ECFS interfaces and data quality will improve public knowledge of lobbying activity