To the Full Comments: http://www.newnetworks.com/FCCbroadbandcomments.htm
Comment Additions
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.
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