Legal & Regulatory

Reports & Documentation Focused on Verizon New York

What FCC proceedings we filed in and what we filed

Filing New York State Public Service Commission,


  • 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
  • Bibliography and Reports

 Follow the Money: Verizon New York 2016 Annual Report:Financial Analysis & Implications –June 22nd, 2017

FCC Comments

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,


This filing is based on other related reports and filings:

The Hartman Memorandum proves that the FCC can never create “just and reasonable” pricing for Business Data Services because the FCC’s own cost allocation rules created massive financial cross subsidies between and among the state-based wired utilities, and the companies’ other lines of business, such as BDS or the wireless service.

The History & Rules of Setting Phone Rates in America are written by telecommunications experts for regulators and interested parties and specifically submitted to the FCC to start to investigations into the cross-subsidies.

The “Fixing Telecom” Report Series 

Many of the IRREGULATORS have collectively and with different partners and companies have  been publishing reports and doing filings at the FCC and State commissions over the last decade, as well as  taking legal actions.  Our report series started as part of New Networks Institute.

We have also filed in current FCC proceedings with Consumer Federation of America.