SUMMARY: Consumers Union, the policy and mobilization arm of Consumer Reports, comments in support of the petition from EPIC et al. for a rulemaking to repeal 47 C.F.R. § 42.6. Under Section 42.6, telephone companies are required to retain 18 months of sensitive consumer data. The law enforcement and commercial justifications for this rule have significantly eroded. Yet it forces companies to retain data in violation of the concept of “minimal data collection,” which is found in privacy regimes worldwide and indicates that information collected from the user is limited to data that is directly relevant and necessary for the service. Data minimization is a necessary protection against harmful breaches of personal consumer data.