Legal & Regulatory

Research, Data, and State and FCC Filings, 2014-2018

 

New Networks Institute & the IRREGULATORS filed in over 35 separate FCC  proceedings and created “Fixing Telecom” series.

  • New Report: Solving Net Neutrality: We Found a Fatal Structural Flaw in Every FCC Proceeding”.  We believe this can be used to take the FCC to court in the Net Neutrality decision and other proceedings.

Partial List of the Proceedings We filed in:

Net Neutrality Internet Order

  • Restoring Internet Freedom WC 17-108

Section 706

  • Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, (Section 706) GN 17-199

Shut off the Copper Proceedings

  • Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment   Report and Order, Declaratory Ruling, and Further Notice of Proposed Rulemaking – WC Docket No. 17-84
  • Technology Transitions, GN Docket No. 13-5;
  • AT&T Petition to Launch a Proceeding Concerning the TDM-to-IP Transition, GN Docket No. 12-353

Wireless Replacement of Wired Services

  • Wireless Infrastructure NPRM Notice of Proposed Rulemaking and Notice of Inquiry – WT Docket Nos. 17-79 and 15-180

FCC Cost Accounting Rules

  • Comprehensive Review of Part 32 Uniform System of Accounts Docket 14-130
  • Jurisdictional Separations and Referral to the Federal-State Joint Board CC Docket No. 80-286

Business Data Services (Special Access)

  • Business Data Services in Internet Protocol Environment, Docket No.16-143;
  • Special Access for Price Cap Local Exchange Carriers, WC Docket No. 05-25;
  • AT&T Corporation Petition for Rulemaking to Reform Regulation of Incumbent Local Exchange Carrier Rates for Interstate Special Access Services, RM-10593.
  • Investigation of Certain Price Cap Local Exchange Carrier Business Data  Service Tariff Pricing Plans Environment WC Docket No. 15-247

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 The Details:

Shut off the Copper Proceeding Filings

  • Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment   Report and Order, Declaratory Ruling, and Further Notice of Proposed Rulemaking – WC Docket No. 17-84
  • Technology Transitions, GN Docket No. 13-5;
  • AT&T Petition to Launch a Proceeding Concerning the TDM-to-IP Transition, GN Docket No. 12-353
  • Also filed in FCC WTB 17-79, GN 17-83, GN 13-5, WC 12-353, CC 80-286

Internet Order

  • The Book of Broken Promises: $400 Billion Broadband Scandal and Free the Net is a encyclopedic collection of state-based Fiber optic deployments. It has been filing in multiple FCC proceedings in 2017, including Restoring Internet Freedom WC 17-108

Internet Order: Verizon’s Use of Title II vs  FCC of Title II’s Harms

  • NNI have filed a Petition for the FCC to investigate whether Verizon has committed perjury as Verizon has failed to disclose to the FCC, courts or public that their entire financial investments are based on Title II; filed Jan 13th, 2015.
  • Verizon has responded with a letter denying our claims, filed, Jan 20th, 2015
  • New Networks Institute & Teletruth Response to Verizon, Feb 23rd, 2015
  • Verizon: Show Us the Money PART I: Verizon’s FiOS, Fiber Optic Investments, and Title I. – Part 1: supplement original Petition for Investigation.
  • Letter to the FCC, Comments: Open Internet proceeding. RE: Verizon’s Fiber Optic Networks are “Title II” — here’s What the FCC Should Do. DOCKET: Open Internet Proceeding, (GN No.14-28)
  •  Comments First: FCC Open Internet Proceeding “Title Shopping: Solving Net Neutrality Requires Investigations” , July 14th, 2014
  • Comment Second: Verizon’s FiOS Fiber to the Premise (FTTP) Networks are Already Title II in Massachusetts, Maryland, Florida, New Jersey, District of Columbia, Pennsylvania, New York 

Section 706 and Related Filings

  •  Comment1,  Comment 2  Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, Section 706 Inquiry GN 17-199
  • NNI: 20 Years of Section 706 and related inquiry filings—New Networks and our previous iteration, Teletruth and current affiliate IRREGULATORS have filed over 20 times over the last 20 years in Section 706
  • http://newnetworks.com/20yearssection706/
  • Part II: Facts Missing from the FCC’s Section 706 Broadband Reports
  • NNI First Section 706 Inquiry, 1998.

Business Data Services: Consumer Federation of America (CFA) New Networks Institute (NNI) Filings

  • Business Data Services in Internet Protocol Environment, Docket No.16-143;
  • Special Access for Price Cap Local Exchange Carriers, WC Docket No. 05-25;
  • AT&T Corporation Petition for Rulemaking to Reform Regulation of Incumbent Local Exchange Carrier Rates for Interstate Special Access Services, RM-10593.
  • Investigation of Certain Price Cap Local Exchange Carrier Business Data  Service Tariff Pricing Plans Environment WC Docket No. 15-247

Joint Press Release: Consumer Federation of America and NNI

“BUSINESS DATA SERVICE MARKET PLAGUED BY ILLEGAL COST ALLOCATIONS, OVERCHARGES AND EXCESS PROFITS. Consumer Federation of America and New Networks data show deeply anti-competitive, anti-consumer practices.

REPORTS: Fixing Telecom Series

In December, 2015, we released the first two reports in a new series, “Fixing Telecom” a project that started seven years ago. They  are based on mostly public, but unexamined, information, the findings impacts all wireline and wireless phone, broadband, Internet and even cable TV/video services in America.

REPORTS:

FILINGS:

On December 16th, 2015, we filed the first  reports in 31 separate FCC proceedings.

FCC Comments: Joint Board & FCC Cost Accounting Rules.

We filed comments and refreshed the record in CC 80-186, WC 14-139, CC 80-286, CC 96-45, CC 97-21, WC 05-25, WC 10-90, WC 12-353, GN 13-5, GN 15-191, WC RM-11358

On May 24th, 2017 the IRREGULATORS  filed comments with the FCC and the Federal-State Joint Board. They 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
  • On May 15th, 2017 the FCC denied our call for audits of the FCC’s accounting rules and granted itself an extension, even though the FCC froze the way expenses were assigned to the different lines of business — but always having ‘local service pay the majority of costs.
  • On April 17th, 2017, the  IRREGULATORS filed comments with the FCC calling for the Agency  to do audits and investigations of the FCC’s “Big Freeze”. The FCC’s accounting rules were ‘frozen’ 16 years ago and they  have created massive financial cross-subsidies, making local phone customers pay the majority of expenses for all services, from wireless to Broadband Data Services (BDS).

This is important because it documents that the FCC can not create new public policies without accurate financial data,

“We refresh this record, again, with ‘Fixing Telecom’, a report series done as an independent voice, without corporate or political financing, because sometimes the Public should come first.”

  • Report 5: The Hartman Memorandum
  • Report 6:The History & Rules of Setting Phone Rates in America— The FCC’s ‘Big Freeze’ & Cross Subsidies
  • Report1: 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.
  • REPORT 4: Data Report Proving Verizon’s Wireline Networks Diverted Capex for Wireless Deployments Instead of Wiring Municipalities, and Charged Local Phone Customers for It.

 FILINGS:

IRREGULATORS’ RESEARCH & ANALYSIS USED IN  MULTI-BILLION DOLLAR INVESTIGATION OF VERIZON NY–POSSIBLE SETTLEMENT, Filed August 8th, 2017

  • COMMENT 1: Overview and bibliography
  • COMMENT 2: : Verizon NY in Multi-Billion Dollar Settlement Tangle, Underway in NY State. (Originally published in Huffington Post as summary).
  • COMMENT 3: Full Report:  Follow the Money: Verizon NY 2016 Annual Report Financial Analysis and Implications

Verizon State Based Reports and Analysis