The evolution of lobbying coalitions in FCC proceeding 01-92 on inter-carrier compensation

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

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

3. Conclusions Graph-theory clusters representreal-world alliances Tracking the evolution of clusters can reveal shifts in alliances Improving ECFS interfaces and data quality will improve public knowledge of lobbying activity

4. Co-filing Analysis Metadata from FCC ECFS database, FCC docket 01-92, April 2001 –December 2008 2,9015 filings, 756 unique filers Subsidiaries and “doing business as” entities are usually grouped together e.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 Wireless Sub-set of FCC docket 01-92 where two or more entities file together Entities that only filed on their own are not shown Used either metadata given as multiple entity names, or extracted entities from filed documents where “et al.” or “filed on behalf of” given in metadata Trade associations and coalitions have not been unpacked into their constituents Sometimes distorts data, e.g. AT&T is represented both on its own account and hidden within the “Missoula Plan Supporters” node Coalitions unpacked: Oregon Rural LECs, Five State Regulatory Commissions, Coalition for Rational Universal Service and Intercarrier Reform Companyname changes on acquisition/merger not accounted for: Frontier Communications Corporation was formerly known as Citizens Communications Corporation Don’t distinguish between “old” and “new” AT&T, or Verizon before and after MCI merge

5. Filing intensity varies over time FNPRM issued 11/5/08 Responses (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)

6. Links between 01-92 and other dockets Petition of AT&T for interim declaratory ruling and limited waivers pleading cycle established IMPLEMENTATION OF THE LOCAL COMPETITION PROVISIONS IN THE TELECOMMUNICATIONS ACT OF 1996 In the Matter of Establishing Just and Reasonable Rates for Local Exchange Carriers FEDERAL-STATE JOINT BOARD ON UNIVERSAL SERVICE In the Matter of Universal Service Contribution Methodology Federal-State Joint Board on Universal Service 1998 Biennial Regulatory Review ACCESS CHARGE REFORM In the Matter of Inter-Carrier Compensation for ISP-Bound Traffic In the Matter of Federal -State Joint Board on Universal Service High-Cost Universal Service Support Numbering Resource Optimization In the Matter of IP-Enabled Services In the Matter of Lifeline and Link-Up Request Petition for Declaratory Ruling that AT&T's Phone-to-Phone IP Telephony Services are Exempt from Access Charges All 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

7. Companies typically either always file solo, or always jointly 498 entities always filed alone, e.g. BellSouth, NARUC 152 entities always filed with someone else, e.g. Broadview, Maine PUC 25 entities filed with others in 40%-60% of cases, e.g. tw telecom, Pac-West Solo filers excluded from co-filing analysis

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

9. Different co-filing occurrences… … lead to a network structure Filed on Date 1 Filed on Date 3 A B A B B A B C C So far the graphs looked at all filings simultaneously. Looking at a sequence of dates shows different links at different times: Filed on Date 2 Date 1 Date 3 Date 2 A B A B A B A B A B C C C C Deriving a Network Structure

10. 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): Size AT&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.

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

14. Nodes are laid out (by hand) to respect clustering Clusters 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

15. A Time Series Underlying data set has day-by-day granularity; these snapshots are integrated over much longer periods

16. 2001-2002 CLEC reply comments to NPRM T-Mobile et al petition for declaratory ruling

17. 2003-2004 CLECs’ “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

18. 2005 – summer 2006 CLECs Major CLECs – FNPRM comments & replies CLECs, some eventually merging e.g. Lightship, CTC, Conversent; and Xspedius & tw telecom Rural LECs and their associations

19. Fall 2006 – end 2007 Missoula Plan Allies Missoula Plan Opponents: Mix of CLECs, ILECs and Indep. Wireless Oregon Rural LECs, supporting Missoula Plan

20. Jan – July 2008 The calm before the storm

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

22. Oct 2008 Five State regulatory commissions objecting to “eleventh hour filings” Small ILECs trying to slow down process Broadening CLEC coalition opposing change towards flat rate Mid-size rural LECs opposing flat rate comp, supporting status quo OPASTCO/WTA Plan

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

24. Summary of Coalition Patterns Opponents are connected: ILECs, CLECs, and cellular Rural LECs and their associations keep to themselves

25. Top 20 Impact Depends on Chosen Metric CLECs 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

26. Observations Graph clusters seem to correspond to real-world interests A 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 alliances In 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 twice Most of them are pairs There are a few large groups of co-filers that show up only once in the record, and aren’t seen before or after Frequent Filers are usually different from Cross-Connectors Frequent filers like AT&T, CTIA and NTCA don’t often file in coalition Connectors that bridge alliances (e.g. Hypercube, iBasis) don’t file all that often Some fall in both groups, e.g. XO and Cavalier

27. Value of the approach Insiders can use graphs to identify: detailed trends at a glance potential collaborators or defectors, e.g. by looking for coalition members who are bridges between groups, or peripheral Outsiders can grasp the overall structure of a proceeding without having to read the entire record News organizations can use: cluster evolution to show changes in coalitions network structure to guide understanding of search results

28. Implications for FCC Poor quality of information input by filers impedes transparency Endless misspellings of company names Not all entities involved in a filing are listed Filers make mistakes (e.g. mistyping docket number) but can’t remove mistakes; they simply file again Require more information in metadata Require all entities names to appear in the Filed on Behalf Of field, i.e. “et al.” not allowed Distinguish between ex parte letters and meetings Use standard web techniques to facilitate data input and retrieval Require log-in with company ID when submitting data to ECFS Require filer name to be registered; subsequently metadata can only be chosen from pre-registered information, not added de novo Offer drop-downs and auto-complete to add co-filers Provide web interfaces for downloading data in bulk, and as daily feeds Improve systems for correcting errors Allow filers to remove incorrect data (only filer can remove what was filed) Penalize errors, e.g. by naming and shaming Invest in cleaning up old data: requires public/private effort?

29. Caveats Graph depends on metadata entered into ECFS by filers, which can be unreliable misspellings (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)

30. Some Bad Data Examples BellSouth: BellSouth Coration BellSouth Corpm BellSouth Corps BellSouth D.C. BellSouth TELECOMMUN BellSouth TELECOMMUNIC BellSouth TELECOMMUNICA BellSouth TELECOMMUNICAT BellSouth TELECOMMUNICATI BellSouth Telecommunication BellSouth Cellular CORPOR Misspellings of “Communications”: Comminication Commnications Communictions Commuications Commuincations Communcations COMMUNIATIONS Communicaitions COMMUNICAITONS Communicatiions Communicatins Communicationas Communicationsn COMMUNICCATIONS Communictions Communocations Comunications Coommunications Cummunications California 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 Commission People 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 Commissoin People 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

31. Caveat (ctd): Coalitions are Understated Analysis puts a lower bound on connectivity Some connections are not revealed through co-filing; entities may be linked, e.g. through participation in a trade association, but not file together explicitly Co-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

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