It's hard to see the steelman case for this. The transcript of their objections at the initial hearing are on page 13 of the transcript [1]
> The FTC's highly prescriptive proposal requiring numerous disclosures, multiple consents and specific cancellation mechanisms is a particularly poor fit for our industry. Our members offer services in a variety of custom bundles. They're provided over a wide range of devices and platforms. Consumers, for example, frequently subscribe to a triple play bundle that includes cable, broadband and voice services. They may face difficulty and unintended consequences if they want to cancel only one service in the package.
> The proposed simple click-to-cancel mechanism may not be so simple when such practices are involved. A consumer may easily misunderstand the consequences of canceling and it may be imperative that they learn about better options. For example, canceling part of a discounted bundle may increase the price for remaining services. When canceling phone service, a consumer needs to understand they will lose 9-1-1 or lifeline services as well. Especially important, low-income consumers could be deprived of lower-cost plans and special government programs that would allow their families to keep broadband service.
I mean, except for the 9-1-1 point, I guess I feel like all of those policies -- the bundling in particular -- should ALSO be disallowed.
Ironically you can counter all these arguments almost perfectly with the inverse:
"Customers may not know what they are signing up for or may only want to sign up for one service rather than the bundle"
But of course, they only feel the canceling part would be bad, not the signing up part (which is also ridden with dark patterns and deception to fool customers).
Exactly, if anything the risks to the consumer of entering into a new contract-for-a-service are overwhelmingly greater than the risks of canceling the same. (Especially for a Disney+ account :P [0] )
>"All wireless phones, even those that are not subscribed to or supported by a specific carrier, can call 911. However, calls to 911 on phones without active service do not deliver the caller’s location to the 911 call center, and the call center cannot call these phones back to find out the caller’s location or the nature of the emergency. If disconnected, the 911 center has no way to call back the caller."
Requiring carriers to enable whatever side-channel is necessary to transmit location info to the 911 PSAP shouldn't be a heavy lift.
The callback issue seems harder to resolve, but even if a handset has no assigned phone number, there are other ways to address it (e.g. IMEI). Carriers should be required to build in a capability to make this work.
> Requiring carriers to enable whatever side-channel is necessary to transmit location info to the 911 PSAP shouldn't be a heavy lift.
Carriers can and they should.
> The callback issue seems harder to resolve, but even if a handset has no assigned phone number, there are other ways to address it (e.g. IMEI). Carriers should be required to build in a capability to make this work.
Carriers can't, because the 3GPP standards do not make this possible.
The one exception to frictionless cancellation could be a big modal warning the customer that cancelling will hamper their 911 service, if what they're doing will actually do so.
> The FTC's highly prescriptive proposal requiring numerous disclosures, multiple consents and specific cancellation mechanisms is a particularly poor fit for our industry. Our members offer services in a variety of custom bundles. They're provided over a wide range of devices and platforms. Consumers, for example, frequently subscribe to a triple play bundle that includes cable, broadband and voice services. They may face difficulty and unintended consequences if they want to cancel only one service in the package.
> The proposed simple click-to-cancel mechanism may not be so simple when such practices are involved. A consumer may easily misunderstand the consequences of canceling and it may be imperative that they learn about better options. For example, canceling part of a discounted bundle may increase the price for remaining services. When canceling phone service, a consumer needs to understand they will lose 9-1-1 or lifeline services as well. Especially important, low-income consumers could be deprived of lower-cost plans and special government programs that would allow their families to keep broadband service.
I mean, except for the 9-1-1 point, I guess I feel like all of those policies -- the bundling in particular -- should ALSO be disallowed.
[1] https://www.ftc.gov/system/files/ftc_gov/pdf/ftc-negative-op...