- Comment 1: is 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 of the current proceeding and Verizon settlement, as published in tbe Huffington Post: Verizon NY in Multi-Billion Dollar Settlement Tangle, Underway in NY State.
- Comment 3: : is a full analysis of the Verizon NY’s 2016 Annual Report Verizon NY 2016 Annual Report: Follow the Money: Financial Analysis and Implications
On May 24th, 2017, the IRREGULATORS filed comments with the FCC and the Federal State Joint Board on Jurisdictional Separations.
We recognize that the Commission has chosen to deregulate the so-called Price Cap Carriers such that to the limited extent that they are subject to rate regulation, it is via a price cap mechanism, not the traditional Uniform System of Accounts. Hence only the Rate of Return Carriers are directly subject to the separations mechanism for the computation of their interstate rates. However, even in the case of the Price Cap Carriers, Separations is a joint federal-state matter, and the freeze imposed by the Commission directly impacted state rates and, even more importantly, policies. Fictitious accounting leads to bad decision-making. Hence the costs of more accurate separations are not an undue burden. Rate of Return Carriers already are required to provide detailed regulatory accounting in order to determine their appropriate rate and subsidization levels. Price Cap Carriers, especially the Bells (including their successors-in-interest) are large companies with ample accounting resources. Thus, the issues we raise are not moot, even when dealing with the largest carriers.
The Federal State Joint Board has asked:
- Re: Federal State Joint Board on Jurisdictional Separations Seeks to Refresh Record on Issues Related to Jurisdictional Separations, FCC 17J-1
- Re: Federal State Joint Board on Separations Seeks Comment on Referral for Recommendations of Rule Changes to Part 36 as a Result of Commission Revisions to Part 32 Accounting Rules, FCC 17J-2
The Book of Broken Promises
“A regulated company will always renege on promises to provide public benefits tomorrow in exchange for regulatory and financial benefits today.”
America’s households and businesses have been overcharged at least nine times for broadband/fiber optic services, including the wiring of schools, libraries, and hospitals— about $4000-$7000 per household, and the total is way over ½ trillion dollars by 2016. You can thank just a few companies: AT&T, Verizon and Centurylink, who control the state-based utilities, along with the cable companies, Comcast and now-Spectrum et al. And this is the low number.
The 3rd book in a trilogy that started in 1998, “The Book of Broken Promises” by Bruce Kushnick, proves that few have a clue about the factual history of broadband, much less fiber optic deployments in America that customers paid for, especially the FCC.
April 2017 was Infrastructure Month at the FCC; shame you weren’t told the truth. FCC Chairman Ajit Pai, a former Verizon attorney, has been making sure you hear the fake history of broadband and the Internet, which is being used to create exceedingly harmful public policies, and this needs to be stopped, now.
And regardless of what you heard, Verizon, AT&T and CenturyLink control the state telecommunications utilities, such as Verizon NY or AT&T-California, a fact that has been erased. And the copper wires, as well as most of the fiber optic wires are part of these state utilities, including those used for FiOS or the wires to the cell sites, or all of the other ‘business data services’ (BDS). And they have been funded mainly by local phone customers—and are classified as something called “Title II”.
(Yes, AT&T and Verizon are also wireless companies, and ISPs, and cable companies, and broadband companies, and more recently ad-tech and entertainment companies. However, almost all of it uses the state utility wires, especially in their own territories.)
Here’s What Actually Happened (For details, download the book.)
I believe that the potted plants, as shown in the picture above, are not a substitute for the two FCC commissioners that are missing from this picture and should be helping to add balance to the lopsided reign of terror currently underway. While three FCC commissioners legally constitutes a quorum, I’d trust the votes of the potted plants, (Dieffenbachia, I believe) over this group.
There are supposed to be 5, I repeat, 5 commissioners at the FCC. There are now only 3, with only 1 person, Chairman Ajit Pai, a former Verizon attorney, calling the shots. (More likely, there is undue influence from the Executive branch making decisions to remove basic privacy rights and coming up— to trash Net Neutrality.)
On April 20th, 2017 the FCC is going to have a meeting and it is going to be a consumer and competitor bloodbath. The FCC has already put forth their proposed rules in multiple areas, including the “IP Transition”, to the hotly contested “Broadband Data Services”. But, the overall plan is to remove all regulations and obligations on the incumbent phone utility companies: AT&T, Verizon and Centurylink. (You didn’t know that they are still ‘utilities’?)
In short, this is an all out assault on the public interest. And I’ll come back to what’s about to happen in a moment.
Just to recap, the new FCC Chairman, Ajit Pai, has taken control of the FCC with the help of his other Republican Commissioner, Michael O’Rielly. This has left a vacuum and a guarantee that there will be no serious discussion of any FCC decision because there is one Democrat, Mignon Clyburn, and she is not a lawyer. There was initially some lip service to have a former Dem Commissioner, Jessica Rosenworcel return, but that would have created, well, a stalemate with 2 Dems and 2 Republicans.