IRREGULATORS & NNI Reading Library


The Case to Break up Big Telecom & Cable, April 2021

Summary for Normal People:

 Communications Prices

Wireless Prices are Out of Control

 The “Triple Play” Prices are Out of Control.

Added Made Up Fees with No Audits and No Government Mandates

No Truth in Billing

No More Taxes, Fees, Surcharges

MARKET POWER: Takeover of FCC, State Legislatures, Media

The takeover of the FCC ro the capture and control of the Consumer Advisory Committee, as ewll as state legislatures and commissions.



  • In 2019, the IRREGULATORS took the FCC to court over the FCC accounting rules that have become deformed but are still in use. The DC Court of Appeals gave us the decision we wanted—the states are independent of using the FCC’s FCC USOA, Uniform Standard of Accounting and can go after the massive cros-subsidy scheme we uncovered.

History of Fiber Optic Deployment Failure in America     

This trilogy of books started in 1999, but the first book was based on one of the largest research projects undertaken to examine the break up of AT&T and the formation of the Bell companies, with Probe Research,1993-1995

Broadband and Accounting States Covered

New Jersey



New York


California Recent Activities, 2021

Articles on 5G and Wireless

Aug 11, 2020 The FCC has decided that it should give $9 billion for the deployment of wireless 5G, but the FCC has never …

Access Line Accounting has been Manipulated

  • Bell Access Line Accounting Manipulation 1984-2018
  • Description: Verizon, AT&T, CenturyLink, and their association, USTelecom, with the help of the FCC, have manipulated the basic accounting of access lines, and have removed or hidden 80% of all lines, including all Business Data Services, (special access) DSL, competitor lines, FiOS, U-Verse, all of the wires to the cell sites or WiFi hot spots, alarm circuits, and this has been done to reinforce a claim that the utility networks are unprofitable.

Killed Off Competition

Statements by Executives and Regulators

What the Bell executives tell the investors, but hides from the public.

  • 5G: The Wireline-Wireless Bait & Switch: Because It Makes Them More Money. A full report detailing statements of executives pertaining to the deployment of Wireless – as a money maker and highlighting what the companies do  not what they tell the public.

Bell Mergers and Outcomes

Business Data Services and Accounting Overcharges

Consumer Federation of America (CFA) New Networks Institute (NNI)

  • Consumer Federation Ex Parte Meeting with the FCC, September 2016
  • Reply Comments Filed, August 2016
  • Joint Comments Filed
  • Consumer Federation of America and New Networks Institute data show deeply anti-competitive, anti-consumer practices On June 28th, 2016  New Networks Institute and Consumer Federation Filed Joint Comments in the FCC’s Business Data Services Proceeding.

Joint Press Release: Consumer Federation of America and NNI

Decade of Examination: Verizon NY Reports & Filings, 2010-

New York is the only state that requires a full financial annual report. Starting in 2010, NNI’s team started to find some unsettling financial transactions and business practices, which we later uncovered was happening in every state.

  • Verizon’s State-Based Financial Issues & Tax Losses: The Destruction of America’s Telecommunications Utilities
  • In 2010, NNI started an investigation of the financial books of five Verizon’s state-based utility phone companies, including Verizon New York and Verizon New Jersey and the ties to Verizon Communications affiliate companies, (subsidiaries) including Verizon Wireless, Verizon Online, Verizon Services, among others. Published in 2012
  • Verizon Wireless and the Other Verizon Affiliate Companies Are Harming Verizon New York’s (The State-based Utility) Customers & the State.
  • In September 2013, our next report focused on Verizon New York and was the centerpiece of a filing by Common Cause, Consumer Union, CWA, and the Fire Island Association, which called for an investigation of Verizon’s financials and business practices, Alexander Goldman, Esq. co-authored the report.
  • It’s All Interconnected”,
  • In May 2014, Public Utility Law Project, (PULP) published “It’s all Interconnected”, written by New Networks (with assistance by David Bergmann, Esq.) and it relied on unexamined data from Verizon New York using different Verizon supplied financials books.
  • The Verge: Game of Phones: How Verizon is playing the FCC and its customers, May 2014
  • The Connect New York Coalition, filed a Petition with the NY State Public Service Commission to do a formal investigation of Verizon New York. July 1, 2014. The Petition is based, in part, on NNI’s continuing research.
  • Coalition members include AARP, Consumer Union, Common Cause, CWA, and NY state politicians.
  • NNI & IRREGULATOR FILINGS, NYPSC: August 8th, 2017, we submitted 3 documents: Comment 1 has a short overview as well as a bibliography of our research, which is directly tied to this proceeding. It also gives a brief discussion of issues that have been overlooked or are missing and need to be part of the next steps the State should be implementing. Comment 2 is a more detailed view (that has been published in Huffington Post) of the current proceeding and a Verizon settlement. Comment 3 is a full report based on our analysis of the Verizon NY’s 2016 Annual Report.
  • COMMENT 1: Overview and bibliography
  • COMMENT 2: Huffington Post: Verizon NY in Multi-Billion Dollar Settlement Tangle, Underway in NY State, August 4th 2017
  • COMMENT 3: Full Report: Verizon NY 2016 Annual Report: Follow the Money: Financial Analysis and Implications.
  • Verizon New York 2017 Annual Report: An Analysis of Cross-Subsidies and Customer Overcharging
  • DESCRIPTION: This report, based on the Annual Report, shows that there is a utility and that it is hemorrhaging money because of the FCC.
  • Verizon NY Settlement Story, July 2018. The investigation concluded and Verizon NY settled the case. Estimated at $300-500 million dollars, the settlement called for an estimated 30,000 lines of fiber optics to be installed and the existing copper networks maintained.

Other New York Articles and Filings


How the FCC Accounting Formulas Overcharge America

  • Report 1: Executive Summary: Verizon’s Manipulated Financial Accounting & the FCC’s Big “Freeze”
  • Report 2: Full Data Report
  • Report 3: SPECIAL REPORT How Municipalities and the States can Fund Fiber Optic Wireline and Wireless Broadband Networks.

Proving the Cross Subsidies of Wireless by Wireline Utility and Customers

  • REPORT 4: Data Report Verizon’s Wireline Networks Diverted Capex for Wireless Instead of Wiring Municipalities, and Charged Local Phone Customers.

The Manipulation of the FCC Accounting Rules, Expert Analysis

  • Report 5: The Hartman Memorandum proves that the FCC’s own cost allocation rules created massive financial cross subsidies.

The History and Rules of Setting Rates in America

  • Report 6: The History & Rules of Setting Phone Rates in America
  • Report 7: SUMMARY REPORT: Verizon Massachusetts & Boston: Investigate the Wireless-Wireline Bait-n-Switch, January 17th, 2017
  • Report 8: Verizon NY 2016 Annual Report Analyzed, June 2017.

The Digital Divide by Design The Formation of the Digital Divide by Design

  •  FILED WITH COMMENTS: REPORT 1:  Did AT&T, Verizon, CenturyLink & the FCC Intentionally Create the Digital Divide?

Overcharging: Manipulated Accounting: Cooked Books Nationwide

  • FILED AS REPLY COMMENTS:  REPORT 2: Verizon New York 2017 Annual Report: An Analysis of Cross-Subsidies and Customer Overcharging
  • DESCRIPTION: This report, based on the Annual Report shows that there is a utility and that it is hemorrhaging money because of the FCC.

FCC $9 Billion 5G Giveaway.

The FCC has decided that it should give $9 billion for the deployment of wireless 5G, but the FCC has never examined that there has been a massive cross-subsidies of the wireless networks, where Local phone customers have ended up being charged for the fiber optic networks used by Verizon and AT&T wireless. We filed for the FCC to investigate these cross-subsidies, which include 5G wireless. Click to Read the Filing

FACT SHEET: Verizon Massachusetts Fiber Optic Failure


Verizon Massachusetts Fiber Optic Failure, 1994-2020

1994: Verizon Massachusetts files with the Mass Department of Public Utilities to have fiber optic services, to replace the existing copper wires. The included colleges and universities, hospitals, as well as 330,000 residence and businesses.

1994: This same plan was also filed with the FCC known as “Video Dialtone”, and claimed the majority of the entire state would be finished by 2010.

“NYNEX proposes to deploy hybrid fiber optic and coaxial (HFC) broadband networks that will provide advanced voice, data, and video services, including interactive video entertainment, multimedia education and health care services… “NYNEX plans to deploy this type of network to the majority of its customers by the year 2010.”

1995: Verizon filed and was granted “alternative regulations”, which gave the company

1999: In New Networks institute filed a complaint in Massachusetts outlining how Verizon (then New England Telephone) convinced regulators that they would rewire the state starting in 1995 if the company got massive financial incentives – Deregulation — the removal of regulation that examined and limited their profits. The Massachusetts Department of Telecommunications and Energy, never acted on our complaint.

2005: Verizon announces FiOS and gets some municipality franchises for cable TV

2007: We presented testimony in front of the Massachusetts Joint Committee on Telecommunications Utilities and Energy.

2010: Verizon announces it is halting the fiber optic deployments in all states.

2016:  Bait and Switch: Verizon announced it would be upgrading 100% of Boston and spend $300 million dollars.  Instead, most of this has been a bait and switch to use the fiber optic wires that should go to homes to instead roll out wireless, and 5G Wireless.

We documented the story in articles in Huff Post and Medium.



Huffington Post/Medium articles about AT&T and California



FCC Releases The Smoke & Mirrors Internet-Broadband Connections Report

Click for the FCC Numbers-Only Version of this Exhibit.

As I stare at the various pie charts and exhibits in the FCC’s latest report on broadband in America, “Internet Access Services: Status as of June 30, 2017”, published November 2018, only one thing comes to mind: Congress needs to investigate how this smoke and mirrors data is being used to create harmful public policies.

Back in March, 2011, I wrote about the FCC’s highly inaccurate National Broadband Map Database, where the companies listed did not offer service at my address or at the speeds listed.

Seven years later, and trying to reverse-engineer the number of broadband services, especially the accounting of the “Fiber to the Premises”, FTTP, here are a few startling long-term issues and new discoveries. In the industry, these are some of the dirty, little secrets.

Quoting the FCC, there are various caveats.

§ “Who Files What?

· “All facilities-based broadband providers are required to file data with the FCC twice a year (Form 477) on where they offer Internet access service at speeds exceeding 200 kbps in at least one direction.

· “Fixed providers file lists of census blocks in which they can or do offer service to at least one location, with additional information about the service.

Please notice the words and phrases: “census blocks”, “200Kbps in at least one direction”, “they can” and “at least one location”. We will address them in a moment.

How Big Is One Census Block?

A census block is sort of like the area of a postal zip code. And it is directly tied to a specific geography with people living and working at specific locations. Sounds obvious until you examine how they count these locations.

According to Current 360

“Block groups generally contain between 600 and 3,000 people, with an optimum size of 1,500 people… Each census tract contains at least one block group, and block groups are uniquely numbered within the census tract. A block group is the smallest geographical unit for which the census publishes sample data.”

Smoke & Mirror Competition

The FCC and phone companies claim that there is competition and yet, this next FCC caveat about this data tells us that while the database may show a competitor, you, the customer, may never be able to get service from them.

The FCC writes: