To the Full Comments:


Comment Additions

a) Broadband was 45mbps in both directions in 1992. It required “high definition video in both directions”, the same as the Telecom Act of 1996.  We filed with the FCC since 1998 to change their definition of broadband.


Proof of Speed: See the ebook for more on this topic.


B) The FCC Needs an Accurate History of Broadband. In 1999, we filed a complaint refuting the FCC’s Advanced Network report (for Section 706) as it has ignored or left out thousands of state documents – broadband was still a ‘telecommunications’ service and under state law the upgrades to provide broadband were both state-based as well as federal.

Here are just a few pages from what the FCC missed.

Highlights of Comments and Complaints:  We note that Broadband Scandal’s entire collection of data never made it into the FCC’s reports on broadband.

C)  The FCC’s Data Is Atrocious and Needs Immediate Fixing.

In 2007, we filed a complaint because the FCC’s data being used in virtually every docket had been corrupted. The FCC was giving information about current markets, using data from 1992, 1993, 1994, etc.

D) The Mathematics of Customer Overcharging for Broadband.

We’ve outlined how we derived the overcharging in Broadband Scandal, which was a estimate based on both a top-down approach, examining revenues, profits, depreciation, etc for the total company, as well as a bottom up approach, examining the costs by state. This work was upgraded in our 25th Anniversary Report. However, it is clear that this process would include both state and federal investigations as state laws were violated, not to mention federal laws  because ‘multiple states’ used the same fraudulent data; thus, the issues cross state lines. Also, the money is still being collected today as virtually all state laws were never reversed, even though the companies failed to upgrade the PSTN.


Track Record and Data

New Networks has one of the best track records on predicting the future. In our book, (and now ebook), “The Unauthorized Bio of the Baby Bells”, published in 1998, we created a list of issues that needed to be addressed immediately --- and they ALL ended up being a predictor of harm, from the failure of now-AT&T, Verizon and Qwest to properly upgrade their networks, the FCC’s failure to collect accurate data, which then helped to create faulty regulations, or the harms the mergers and market consolidation would have on competition. ALL of our predictions were tied to one conclusion – the path we were on would end up harming customers with less choice, higher prices and no national broadband plan.  – In short, we told you so.

  • 25th Anniversary Conference Online.  – Hear from experts about the last 25 years and what changes are needed as we move forward. --- Online video.