You’re drunk FCC, go home

I just chimed in to the FCC to request that they stop the merger of Comcast and Time-Warner Cable. I don’t know if my voice will make a difference, but I do know that saying nothing will definitely not make a difference.

Here was my statement to the FCC (flawed, I’m sure, but I hope the intent and sentiment is conveyed):

Allowing the merger of Comcast and Time-Warner Cable will dramatically decrease consumer benefits and choice.

Some mergers can be good, allowing struggling companies to reduce losses; in this case, neither Comcast nor Time-Warner Cable is in a situation that needs this merger for financial stability; both companies are currently thriving in the marketplace.

Innovation and an open market for goods and services is in the best interest of the American people. This was clearly shown when the Bell System was broken up January 8, leading to the emergence of advanced competitive services, including cellular phone service, and lower prices. The FCC should take that as a model, and decrease the monopolistic merger of competitors, which decreases this innovation, price competition, and customer choice. Customer service is already notoriously poor at both companies, and decreasing customer choice is likely to make it harder for customers to receive adequate service.

Without competition, Internet providers have little incentive to provide either improved service or lower prices. The US is already widely regarded as having relatively expensive and slow Internet service compared to other industrial nations, and this merger threatens to make that worse.

In addition to the loss of benefits to the consumer, this merger threatens American jobs. When a merger occurs, service departments also merge, and workers lose their jobs. This is especially true when the mergers are in similar industries; some studies have shown an average of 19% job loss, far above the norm of 7.9% when the industries are unrelated. Comcast currently employs 136,000 people; Time-Warner Cable currently employs 51,600 people; if the average job loss takes place, that could mean approximately 35,644 jobs lost, or more conservatively 14,820 jobs, in a still-struggling employment market; many of these will be unskilled labor, which is even harder to resolve. While no laws in the US take into account the effect of job loss on mergers, this is still a factor that can be taken into account by the FCC; laws are only necessary when systemic problems arise in the behavior of key industry players and regulators, and allowing this merger could necessitate the creation of a law that would otherwise be avoided.

Please take the necessary steps to block this merger.

If you are a US citizen, you have until August 25th, 2014 to file a comment. The FCC seems to have gone out of its way to make this difficult, so here are some step-by-step instructions:

  1. Fill out the Free Press petition first just in case. Then, if you want to register your opposition independently…
  2. Go to the FCC  Electronic Comment Filing System page
  3. Enter “14-57” in the Proceeding Number field; you’ll get no immediate confirmation, but this is the code for the “Applications of Comcast Corporation and Time Warner Cable Inc. for Consent to Assign or Transfer Control of Licenses and Applications”. (Note: this is not arcane at all. That’s just an illusion.)
  4. Fill in all required personal information
  5. Ensure that the Type of Filing field is set to “Comment” (the default)
  6. Write a text document explaining why this is such a bad idea; crib mine if you like, or find a much better rationale, but be sure to be clear in your opposition (or support, if you’re a masochist).
  7. Upload your document using the Choose File button. (That’s right, you can’t just leave a comment in a text area, you have to write a separate document. The FCC seems to accept at least .txt and .doc files.) Add your optional description of the file in the Custom Description, so they know your sentiment even if they don’t open your file (which is pretty likely); I labeled mine “Block Comcast-TWC merger”.

Yay! You live in an arguably democratic country!