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New York’s Rural Broadband Program Betrays Tens of Thousands of Rural Residents

For 76,783 homes and businesses in upstate New York, the future of internet access will be a satellite dish and as little as a 20 GB data allowance per month, courtesy of the New York State Broadband Program Office’s decision to partner with HughesNet, a satellite internet provider, instead of finding a provider willing to extend wired internet access to every New Yorker.

HughesNet Satellite “Fraudband”

For town supervisors and village mayors up and down the state, relying on HughesNet is nothing short of breaking Gov. Andrew Cuomo’s promise to bring broadband service to every New York resident.

Lewis town supervisor James Monty called HughesNet and other satellite internet providers “a dead end.”

“HughesNet is not broadband,” Monty said. “I just think it’s a gross waste of public funds to use something that isn’t going to work.”

Rural residents strongly agree, if only because many of them have directly experienced the pain and frustration of satellite internet in the past.

Bethel resident Susan Harte has two words to describe the kind of service HughesNet has provided since it launched its first satellite: “it stinks.”

She isn’t pleased the governor is walking away from rural New Yorkers.

“Definitely broken promises there,” Harte says.

In the North Country, Willsboro town supervisor Shaun Gillilland believes the issue is personal between the governor and his constituents.

“The state made a promise and you’re all here expecting them to carry through on that promise, and I think what we’re finding is that that promise is falling very short,” Gillilland said.

Further west, some residents in Niagara County, near Niagara Falls, are preparing to abandon their homes and move out of state to find internet service and a state government less beholden to corporate interests.

One resident of Middleport tells Stop the Cap! “I’m in a state of disbelief that we are going to actually pull the kids from school and move. We don’t have anymore years to wait. We need internet.”

This particular resident has called out state and elected officials for months on social media to draw attention to the reality rural New Yorkers are going to be stuck with awful internet access for years, while Gov. Cuomo takes credit for a program he will claim is a success story.

A 20 GB Data Cap

HughesNet plans for New York customers at designated addresses for New York’s rural broadband program top out with a 20 GB data cap.

HughesNet appears to be ready to take $15,620,785 from New York and $13,720,697 in private and federal funds and leave residents with internet service even worse than they offer many of their regular customers.

“I’ve already been told by an insider [the only significant benefit New York is getting] is $200 off installation,” the Middleport resident tells us. “The service is exactly the same as ordinary HughesNet except NY Broadband Program Office recipients will have a 20 GB data cap instead of the 50 GB data cap offered elsewhere.”

Susan Potter, who lacks internet access to her home near Watertown, thinks there is a scam afoot.

“Why is New York giving HughesNet $15 million dollars for internet service that any New York resident could order themselves today?” she asked Stop the Cap! “Where is the money going and how exactly will it benefit New York residents? Except for a much smaller and completely inadequate data cap, I cannot find a single thing HughesNet is doing for New York except taking the government’s money for substandard internet access and giving us a break on a satellite dish that can already be discounted from promotions.”

HughesNet’s own website tells an interesting story. Residents who enter an address designated to receive satellite internet by New York are offered just two plans — 10 GB and 20 GB per month (with a 24-month term commitment). Outside of those areas, HughesNet offers up to four plans — 10, 20, 30 and 50 GB allowances per month (with the same two-year term commitment). HughesNet promises “up to 25 Mbps” but disclaims any responsibility if it fails to meet that speed.

“NYBPO officials cannot seem to understand that the technology has limitations and that they can’t offer unlimited data,” the Middleport resident and Stop the Cap! reader added.

Few Albany residents working for the state government have to contend with no internet options, and wired internet plans in New York remain uncapped with no data allowances, which may mean some public officials have yet to grasp the implications of a 20GB data cap, less than what wireless phone companies offer state residents with unlimited data plans. The average home broadband user now consumes an average of 190 GB of data per month, which means HughesNet’s offer is for strictly rationed internet access.

HughesNet plans in parts of North Carolina offer up to 50GB of access.

Back in Lewis, Michael Hopmeier, president of Unconventional Concepts, which provides engineering consultancy services, told the Adirondack Daily Enterprise he openly fears New York’s broadband future has been left in the hands of unqualified bureaucrats running the state’s broadband office:

“I found as an engineer and a person with a background in communications and testing evaluation, that the information that they were providing was completely unrefined,” Hopmeier said. “We were getting broad, vague numbers like ‘99 percent coverage.’”

He said he compiled a list of questions: 99 percent coverage of what? What exactly did they mean by “broadband?” Why were the contracts issued to the companies that they were? Then he and the supervisors filed a Freedom of Information Law request to the state for answers.

“The gist of the responses we received was either no answer, ‘We won’t answer that,’ or the answers made very little sense,” Hopmeier said.

With tens of millions of state taxpayer dollars on the table, Hopmeier worries the state is going to waste a huge amount of money on an unworkable solution for rural New Yorkers.

“My concerns boil down to: one, ‘How are they measuring what they are doing? Two, is there an audit going on? Is there an attempt to review and determine whether those standards and goals are actually being met? And then three, what actions will actually be taken to correct any problems if we can find them,” Hopmeier said.

He has experience using HughesNet himself, and as a result of what he calls “totally technically unacceptable” internet service, he is now sending work out of state to Virginia and Florida, where broadband service is better.

Two hours north of New York City, it is not difficult to find a broadband desert. Steve Israel, writing for the Times Herald-Record, notes Sullivan County communities like Bethel, Callicoon and Delaware, along with Ulster County towns like Marbletown and Rochester are going to be stuck with fixed wireless at 2 Mbps, HughesNet at 15 Mbps (assuming it isn’t congested that day) or for a precious few — Charter Spectrum, which is rebuilding its rural cable systems to support faster internet speeds. For others, DSL from Verizon claims to offer up to 15 Mbps, but few admit to getting service anywhere close to that speed. All of these rosy speed predictions come from the state, but residents on the ground know better.

“Thousands of folks will be left without the high-speed internet Cuomo promised,” Israel wrote.

Frontier’s Internet Nightmares – “They Talk a Lot and Don’t Accomplish Much”

HughesNet isn’t the only provider attracting crowds armed with pitchforks and torches. Frontier Communications, which was recently awarded $9.7 million to extend DSL service to 2,735 more rural customers in the Finger Lakes, Southern Tier and North Country, attracts scorn from its existing customers.

“There is a special place in hell reserved for Frontier’s despicable DSL service,” scowled Lillian Weber.

“Disgustingly inadequate,” fumed Wilmington resident Bob Rose, who has been at war with Frontier for months about slow or intermittent service.

“It’s like not having internet access at all — dial-up used to be faster,” added John Schneider, another unsatisfied customer.

Weber holds the record among her neighbors for the longest delay for a Frontier repair crew to show up — eight weeks, resulting from three “missed” appointments.

“They rarely bother to show up and once claimed they were here but nobody answered the door, despite the fact we spent all day on the porch staring at the driveway,” Weber. “They are even bad at lying.”

Last winter, Wilmington residents found several examples of neglected Frontier lines under pressure from overgrown tree limbs and branches. (Image courtesy: The Sun)

Rose is never sure if Frontier’s repair crews will turn up at his home either when his internet service fails, which is often.

“If I’m lucky, we have an internet connection 60 percent of the time,” Rose told The Sun. “We’ve been frustrated as hell over here, a lot of calls. We might have 1 in 10 days where we have internet all day.”

Frontier says Rose lives in a troubled, “high volume area.” Rose says his entire neighborhood has three or four homes. He now never leaves home without his Wi-Fi hotspot, because it is often the only way to stay connected.

Rose can point to at least one visible problem he saw last winter around his neighborhood. Frontier is simply not taking care of its network.

“It’s unbelievable,” he said. “Tree limbs, heavy with snow, laying right on the cable. They need to trim those trees.”

Local government officials also hear often about Frontier. Essex County Board of Supervisors chairman Randy Preston is one of them.

“Every other week, I get a complaint about Frontier,” he said. He has personally filed a complaint with the state’s attorney general and is sending a call-out to all Frontier customers dissatisfied with their internet service to do the same. He does not believe Frontier deserves a penny of state money, and the company should return what it has already received.

Essex County Board of Supervisors chairman Randy Prestonon Frontier: “They talk a lot and don’t accomplish much.”

“As far as I’m concerned, they haven’t met their commitment,” Preston told The Sun. “The grants should be pulled from them, and they should be fined. They aren’t living up to their commitment, and I don’t think that should be allowed.”

After years of dealing with Frontier, Preston has a saying about the phone company: “They talk a lot and don’t accomplish much.”

The requirements of the current round of broadband funding require participants to offer customers 100 Mbps of service, something a Frontier spokesperson confirmed.

“In general, the program requires projects to have speed capability of 100 Mbps. The Frontier projects will satisfy this requirement of the program,” the spokesperson said.

That will likely require the phone company to bring fiber to the home service to the 2,735 customers to be served. Current customers will believe it when they see it. It is also clear that existing customers will not be so lucky. When asked directly if Frontier will upgrade to fiber-fast internet speeds elsewhere in New York, Frontier Communications manager Andy Malinoski kept his answer to The Sun vague.

“Frontier is constantly investing in, expanding and improving our network as we continue to improve our customer experience in New York and across the United States,” Malinoski said. “The NY Broadband Program is one tactic we are implementing in certain communities to achieve those goals.”

The NY Public Service Commission urges New Yorkers with Frontier DSL problems to complain directly to them.

“If it were to receive a consumer complaint, PSC staff would work to resolve the issue, including bringing in other agencies if necessary,” said James Denn, a spokesman. “Going forward, all upstate New Yorkers will see dramatic improvements in service quality and availability as a result of Gov. Cuomo’s nation-leading investment program. As part of this effort, PSC staff will work closely with the NYBPO to ensure that companies receiving awards, including Frontier, provide good customer service.”

“That’s a hoot,” responded Weber. “They should spend a week with us and after that, if they are smart, they will throw Frontier out of New York right behind Charter.”

Verizon 5G Hype vs. Reality: Widely Unavailable and More Like a “Live Beta”

Phillip Dampier September 18, 2018 Consumer News, Verizon, Wireless Broadband 2 Comments

A Verizon 5G small cell installed in Sacramento. (Image courtesy: ZoraQ)

Consumers hoping for the imminent arrival of a “cable killer” from Verizon’s new millimeter wave 5G fixed wireless broadband should not hold their breath.

Verizon executives have been paraded out to celebrate its debuting 5G service as “revolutionary/game changing/transformational” at the same time Qualcomm, which helped define the forthcoming 5G standard claims it will be “as transformative as the automobile and electricity.”

But the ‘Revolution of 5G’ will not be the next fall of the Berlin Wall or Arab Spring. Those revolutionary changes happened almost overnight. Instead, 5G will be quintessential American capitalism at work: overhyped promises to excite the public and attract investors, tempered by the reality that massive amounts of money and at least a decade of work will be needed to blanket only parts of the country with small cells and the newly ubiquitous fiber optic networks required to connect them together.

Verizon already offers hints of that reality, but only in the fine print where it acknowledges its wireless home broadband replacement service, set to launch on October 1, will be only available in parts of four U.S. cities. Verizon isn’t saying what percentage of Sacramento, Los Angeles, Houston, and Indianapolis will be covered, but enthusiastic would-be customers are crowdsourcing their own coverage maps, and the results are underwhelming.

The City of Sacramento released this map showing Verizon’s planned 5G coverage in the city, but customers dispute it. (Image: City of Sacramento)

“Lightning has hit more homes than Verizon 5G will in Sacramento,” reports Jack Del Vecchio, who spent an hour entering addresses on Verizon’s website looking for service. “The city of Sacramento, trying to placate homeowners worried about more cell equipment visually polluting the city, released a map where Verizon claimed it would be offering 5G service by the end of 2018. That clearly is not happening, at least not yet, because most of these neighborhoods do not have small cells installed yet.”

In Indianapolis, reddit user rycummin_IU scanned almost 17,000 addresses and found Verizon service available to just 179 homes and businesses. Only a fraction of customers in Houston and Los Angeles are qualified for service as well.

The vast unavailability of Verizon 5G service in Indianapolis. (Image courtesy: rycummin_IU)

“When they said Houston would be part of the rollout I didn’t think they meant one street,” commented another reddit user. In reality, Verizon 5G will debut in parts of low-income neighborhoods like Acres Home, Gulfton, Second Ward, Third Ward and Near Northside, at the behest of city officials, among a few others. But availability is very scattered, and based on search results, Verizon is only qualifying customers that live within approximately 500 feet of a small cell antenna.

This map shows the limited range of Verizon 5G small cells. In this case, this neighborhood is likely served by one or two small cells, probably in the vicinity of Sugar and Brady and/or Eastwood or Jenkins St. Notice coverage is often unavailable across streets. (Image courtesy: SmokeyTuna)

The most unlikely choice for limited range 5G is notoriously sprawling Los Angeles, and frustrated residents reported service was least likely to be found there.

“I spent 30 minutes plugging in random addresses all over Los Angeles and I finally found one that works,” reports reddit user chantasic. “It’s the big apartment building at 1108 7th Street, Los Angeles, CA, 90017 in [downtown Los Angeles]. If you go just one block west from there on Garland Ave, it’s not available. If you enter in ‘1127 Lucas Ave Los Angeles, CA 90017’ which is a high-rise, then it starts asking you what floor you live on and whether you have any windows that face 7th St. So one of the antennas must be on 7th St.”

“I put in my work address and it worked at 555 South Flower street, which is across from the library on West Fifth Street,” shared another user. A third reddit reader in Los Angeles managed to track down service at Medici Apartments, a complex next to the 110 freeway in the South Westlake area.

Those customers who are lucky enough to live in a qualified service area report the sign-up process to be orderly. A full credit check is done on prospective customers, and assuming one passes it, an appointment for “white glove” installation is scheduled. Verizon has confirmed no self-install option will be available for the time being. Verizon’s installers are trained to find the best possible place to install its 28GHz antenna, which does not perform well penetrating heavy foliage, certain building materials, and low-energy insulated window glass. Verizon plans to monitor the performance of these early 5G installations to gather more information about how the service is working and how to get the best performance from it.

Verizon has released terms and conditions for the service and provided more insight into the installation process, which takes several hours. Customers interested in more information can call this special Verizon 5G hotline — 1-866-217-2223 to order and schedule installation, or find out about 5G Home.

Verizon 5G Home Terms of Service

Two pieces of 5G Home equipment will be installed at your home:

  • Indoor or outdoor 5G receiver
  • 5G router

The type of receiver (indoor or outdoor) you get depends on the 5G signal strength. If needed, Wi-Fi extenders will be installed in the home, at no charge, to ensure adequate Wi-Fi coverage for the entire house.

What will happen during the 5G Home installation?

An Asurion (third party contractor) technician will complete the following installation process for your 5G Home service and connect your devices:

  • Verify and explain the areas in your home where the 5G signal is received.
  • Conduct a test to determine whether the 5G receiver can be installed inside or outside your home. The strength of the 5G signal can vary inside and outside your home.
  • Conduct a test of the Wi-Fi signal strength of each device throughout the house that is connected to the 5G Home router. A Wi-Fi extender may also be installed at no charge to strengthen the Wi-Fi signal throughout your house or for devices that have a weak Wi-Fi signal.
  • Install the receiver, with your approval, either inside or outside on the side of your house.
  • Depending on the locations of the receiver and the router, the technician may need to run wires through walls, floors or ceilings.
  • Ensure that all your previously Wi-Fi connected devices are now connected to your Verizon 5G Home router.
  • Demonstrate how you can use the My Verizon app to manage your router, such as how to restart it when you are away from home, and check the signal strength of the devices connected to the router.

Service Availability. Unfortunately, we can’t guarantee that our 5G Home service will be available at your address, even if we accepted your order. The 5G Home service does not support static IP addresses.

Equipment. We’ll provide you with equipment, which may include an indoor or outdoor receiver, a router, a Wi-Fi extender, and other equipment, to use with your 5G Home service. That equipment will continue to be owned by us, and you can’t use it for any other purpose, move it to a different location or position, tamper with or intentionally damage it, or allow anyone else to service it. We will repair and maintain that equipment at our expense, unless we determine that you misused, abused or intentionally damaged the equipment, in which case, you will have to pay the replacement cost of it. If any of that equipment is stolen, please provide us with a copy of your police report, so that you are not charged for it.

Installation and Access to Your Premises. We will attempt to install the 5G Home service at the address that you provided to us at the time of sale. From time to time, we may access your outdoor receiver to service, inspect, upgrade and/or remove it. If 5G (or 4G LTE backup) coverage is not available at your address, or if we cannot perform installation for any reason, then we will cancel your order.

Changing Service Location. You may not move the 5G Home service to another address. If you are moving to a new address at which the 5G Home service is available and you wish to continue using it, then please contact us to install it at your new address.

Service Cancellation and Equipment Returns. Upon termination of your 5G Home service, you should return the equipment to us in an undamaged condition (subject only to reasonable wear and tear) within 21 days after service cancellation, or you may be charged an unreturned equipment fee, which may be substantial. If you don’t cancel your 5G Home service, then your service charges will continue to apply, even if you return the equipment. If we ask you to leave the outdoor receiver in place, you will not be charged an unreturned equipment fee.

Comcast & Spectrum Open Up Free Wi-Fi Service in Georgia and the Carolinas

Phillip Dampier September 13, 2018 Charter Spectrum, Comcast/Xfinity, Consumer News, Wireless Broadband Comments Off on Comcast & Spectrum Open Up Free Wi-Fi Service in Georgia and the Carolinas

Hurricane Florence

Comcast and Charter Communications are providing free and open access to more than 12,000 Wi-Fi hotspots in Georgia and the Carolinas as Hurricane Florence begins impacting the three states.

“In response to Hurricane Florence, we have opened up more than 5,100 Spectrum Wi-Fi hotspots in North and South Carolina. These hotspots are open to all users until further notice in coastal communities like Wilmington, N.C., and Myrtle Beach, S.C., as well as inland to the Charlotte, Raleigh-Durham, Fayetteville and Greensboro areas,” Charter said in a statement.

To connect your device, look for the “SpectrumWiFi” network under your device’s WiFi settings in Charter service areas, “xfinitywifi” in Comcast country.

“It’s critical that impacted residents are able to communicate during challenging weather events such as Hurricane Florence,” said Doug Guthrie, regional senior vice president for Comcast.

As a result, Comcast is opening up almost 7,000 hotspots in Augusta and Savannah, Ga., and Charleston, S.C. Both cable companies are welcoming subscribers and non-subscribers alike.

Hurricane Florence, although currently downgraded to a Category 2 hurricane, remains a vast hurricane with a large wind field of hurricane force winds, and will likely pummel the region until Saturday. Combined with intense rainfall and catastrophic storm surges, devastation is likely along coastal regions of all three states. Duke Energy, which serves North and South Carolina, anticipates extended outages for at least three million customers during Hurricane Florence.

As of 5 p.m. ET Thursday, the center of Florence was 100 miles east-southeast of Wilmington, N.C. and 155 miles east of Myrtle Beach, S.C. The hurricane has slowed to just 5 mph.

Other states likely to be impacted by flooding rains, storm surge, and winds are Maryland and Virginia.

Actual landfall of Florence is not expected until at least Friday afternoon, according to Neil Jacobs at the National Oceanic and Atmospheric Administration (NOAA).

Cable outages are often a result of power outages. If electricity goes out in an area, cable services will go as well, and remain unavailable until power is restored. If cable infrastructure is also damaged, service won’t return when electricity does and outages should be reported to the cable company. Traditional landline service is powered independent of the electric grid. Report any service outages to the telephone company.

If infrastructure is severely damaged, it could take several weeks to restore electric, phone, and cable service after a major hurricane.

N.Y. PSC’s Diane Burman Objects to Special Session Voting Charter/Spectrum Out of New York

Phillip Dampier September 12, 2018 Charter Spectrum, Consumer News, Public Policy & Gov't, Video Comments Off on N.Y. PSC’s Diane Burman Objects to Special Session Voting Charter/Spectrum Out of New York

Burman

New York State Public Service Commissioner Diane Burman today voted against motions to give Charter Communications more time to develop its six month exit plan to leave New York and a motion to get more time to file a rehearing request about Charter’s alleged violations of merger conditions governing its behavior in the state.

Burman’s opposition was rooted in her irritation over PSC Chairman John Rhodes’ decision to hold an unscheduled special session of the Commission on July 27 (which Burman did not attend because of a scheduled family vacation) where the three remaining commissioners all voted to cancel approval of the Merger Order allowing Charter Communications to acquire Time Warner Cable in New York State.

“I believe it was wrong to have that special session and I don’t believe that the rationale for it is the right one,” Burman told her fellow commissioners this morning at a regularly scheduled Commission Session. “I think it is a slippery slope that there was a special session without me present and that is concerning.”

Burman argued the Commission’s recent approval of time extensions in the Charter case could set a precedent that could take the regulatory agency down a road where companies like Charter and other utilities could delay proceedings by having informal private talks with Commission staff. As a result, Charter has effectively stopped the Commission’s clock on pre-determined deadlines like a 30-day limit to file a petition asking the Commission for a rehearing.

“The message that I fear we are sending is if there is an order that someone disagrees with and they are going to file a petition for rehearing […] if they are engaged in ‘productive’ dialogue, whatever that term may be, between the staff, we can wait for the petition for rehearing to be filed past the 30 days,” Burman argued. “For me, the impactful piece of it is that by saying ‘don’t file now’ we are blocking the [regulatory and public notice] process and the opportunity to start that clock so that people have the opportunity to comment on what we may be doing, which may be helpful.”

Because the Commission has approved delays allowing Charter company officials and the Commission to continue privately discussing matters, none of those conversations are on the public record and no groups, including Stop the Cap!, can scrutinize the discussions and file comments about those conversations, Commission decisions that may result from those talks, or suggest alternative corrective measures to consider.

The PSC’s counsel this morning admitted the Commission and Charter were engaged in active settlement discussions, but it isn’t known if those talks relate to overturning the Commission’s decision to banish Charter from the state or are about more procedural matters such as how Charter plans to hand over cable service to another entity.

“I think there are lessons to be learned from having the special session without me there and I do think that going forward, we need to be more cognizant of taking into consideration what the perception is by not having the full Commission body, minus one because there is a vacancy, [vote together on matters of great consequence like this] regardless of whether counsel believes there is an appropriate quorum or not,” Burman added.

The final vote on both measures extending deadlines in Charter’s favor was 3-1. Both measures passed.

N.Y. PSC Commissioner Diane Burman opposed the extension of the deadline for Charter Communications to file its plans to leave New York State and to request a rehearing of a July decision revoking their merger with Time Warner Cable in New York. (29:26)

Investigation: Spectrum’s Best Discounts Go Only to Areas With Robust Competition

Spectrum customers living in areas wired for fiber optics get substantially better discounts for longer periods of time than those living in areas where anemic phone company DSL service is the only competition.

Charter Communications, like many cable operators, asks all prospective customers to enter their complete mailing address, claiming prices “vary per location.” What the company does not say is that it maintains a database of addresses where fiber-fast competition is currently available and only offers the best deals to those locations.

In Rochester, N.Y., Spectrum competitor Greenlight Networks has made headway installing fiber to the home service in select neighborhoods in the city and suburbs. As fiber service becomes available, some Spectrum customers start switching to Greenlight, which markets 100/20 Mbps service for $50/mo, 500/50 Mbps for $75/mo, or 1,000/100 Mbps for $100/mo. In response, to keep customers, Spectrum offers 24 months of reduced pricing on its internet package. But your address must match Spectrum’s database as being within a competitive service area. Otherwise, the deals will not be so good.

Stop the Cap! found dramatic differences in prices between addresses nearly across a street from one another – one wired for Greenlight Fiber, the other not.

Competitive Area (Spectrum, Frontier DSL, Greenlight fiber-to-the-home service)

Spectrum Ultra (400 Mbps): $44.99/month for 24 months (free upgrade from Standard 100 Mbps package)

All promotions last 24 months

Free Wi-Fi Service

No installation or set up fee*

Non-Competitive Area (Spectrum, Frontier DSL)

Spectrum Standard (100 Mbps): $44.99/month for 12 months (for Ultra 400 Mbps, add $25/mo)

All promotions last 12 months

Wi-Fi Service is $5/month

$49.99 professional installation fee required for Ultra 400 Mbps service*

In Greenlight service areas, Spectrum now undercuts Greenlight’s pricing by offering Spectrum Ultra 400 Mbps service for $5 less than what Greenlight charges for 100 Mbps.

“Racerbob,” a DSL Reports reader in Webster, N.Y., discovered the same “enhanced offers” as an ex-Spectrum customer. He switched to Greenlight three months ago. He discovered if he added a Spectrum cable TV package, the price for 400 Mbps Ultra internet service dropped even lower, to $39.99 a month for two years.

In all, a sample package he assembled delivered dramatic savings, but only if a robust competitor like Greenlight was also offering service to his address:

Addresses used for comparison were in zip code 14618, with verified access to Greenlight at a street address to represent the “competitive” service area and verification Greenlight was not available at the address used for “non-competitive” service area. *-Although a setup fee was found on the final checkout page in both competitive and non-competitive service areas, it was only actually charged in non-competitive service areas during our investigation.

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