Santa Broadband: Ajit Pai’s magical world of broadband

God bless deregulation and your local phone and cable companies for making American Broadband Great Again.

That’s the message FCC Chairman Ajit Pai hopes will be the take away in the forthcoming 2019 Broadband Deployment Report — a highly dubious and over optimistic assessment of America’s rural broadband landscape.

“For the past two years, closing the digital divide has been the FCC’s top priority,” Chairman Pai said. “We’ve been tackling this problem by removing barriers to infrastructure investment, promoting competition, and providing efficient, effective support for rural broadband expansion through our Connect America Fund. This report shows that our approach is working. But we won’t rest until all Americans can have access to broadband and the 21st century opportunities it provides to communities everywhere.”

Except closing the rural-urban broadband gap has been a FCC priority for more than two years, and was a particularly high priority for the previous administration, which devoted a large amount of controversial stimulus funding after the Great Recession to internet expansion during the Obama Administration. In fact, Chairman Pai repeatedly claimed credit for broadband expansion projects that were funded by the previous administration, while at the same time criticizing the FCC under former Chairman Thomas Wheeler for harming investment in broadband with the enforcement of net neutrality.

The FCC continues to rely on dubious and flawed data to produce its reports — unverified data typically volunteered by the country’s phone and cable companies. The FCC has been frequently criticized for relying on inaccurate broadband availability maps, taking providers at their word on broadband speeds that fail to materialize in the real world, and reporting expansion projects that do not directly benefit consumers.

Pai’s office this week released a press release attempting to conflate broadband gains to his deregulatory policies and the banishment of net neutrality.

“The private sector has responded to FCC reforms by deploying fiber to 5.9 million new homes in 2018, the largest number ever recorded. And overall, capital expenditures by broadband providers increased in 2017, reversing declines that occurred in both 2015 and 2016.”

But Pai does not offer any evidence to back up those claims. In fact, as Stop the Cap! has reported, many of the country’s largest telecom companies have been cutting capital expenditures, many initiated as part of system upgrades to convert to digital cable television or to increase the amount of fiber optics to increase cable system reliability — neither relevant to the debate about net neutrality. This year, Charter Communications has announced a dramatic drop in spending (despite the repeal of net neutrality) because their long-planned system upgrades surrounding the retirement of analog cable television are now complete. Charter also had its merger agreement with Time Warner Cable revoked in New York for failing to meet its rural broadband commitments in that state.

Comcast cut spending by 3% because it bought fewer set-top TV boxes in light of cord-cutting customer losses. Verizon, which has been aggressively promoting its forthcoming 5G millimeter wave wireless network, slashed spending from $17.2 billion in 2017 to between $16.6-17 billion last year, and a significant sum of that money was earmarked for 5G buildouts in urban areas, not expanding rural internet. AT&T’s capital expenditures for 2019 are not expected to move much, placed in the $23 billion range for 2019, just a little more than last year. But AT&T is expecting to be reimbursed $1.6 billion by the federal government for AT&T’s FirstNet public safety network buildout, and much of its other spending is targeting its wireless business, including a plan to launch 5G services in 19 cities this year. That means less money for AT&T’s wireline network, including fiber broadband for homes and businesses.

Pai’s claims about the increased availability of broadband, at higher speeds, comes largely at similar incremental rates to progress under the Obama Administration. In New York, which is seeking to approach near universal broadband coverage, what moved the needle the most was a large sum of funding available to subsidize rural broadband expansion. The availability of substantial financial assistance from the state government, which some described as corporate welfare, appeared to be the most effective broadband expansion motivator for an industry Pai praised in his press release, not deregulation or the repeal of net neutrality.

The Democrats are countering the Trump Administration’s economic proposals with plans of their own they broadly call “A Better Deal.”

Democrats in Washington are countering President Donald Trump’s lack of commitment to earmark funding for rural broadband with a $40 billion plan of their own that is part of a broader trillion-dollar infrastructure investment package released Wednesday.

The plan, “Returning the Republican Tax Giveaways for the Wealthy to the American People,” specifically targets funding for a new, last-mile focused, broadband expansion program that would target funding specifically to providing broadband service to the homes and businesses in the country that cannot get the service now.

“The electricity of 2017 is high-speed Internet,” according to the Democrats. “While the private sector has delivered high-speed internet to many, millions of Americans in less profitable rural and urban areas have been left out.”

Rural broadband is expected to become a campaign issue in the midterm elections, as Democrats push their new working and middle class recovery program they call “A Better Deal,” reminiscent of President Franklin D. Roosevelt’s “New Deal” program during the Depression of the 1930s.

The Democrats claim they will do a better job overcoming the digital divide by forcing providers to compete for public funding. In contrast, the Trump Administration’s general infrastructure program offered $200 billion for all types of infrastructure projects, with no funding earmarked for broadband. But most of that money can only be unlocked if a private company enters into a public-private partnership with the government and agrees to invest even more in private dollars than the federal government will offer in supplementary funding.

The Democrats also claim their broadband investment program will be open to public providers like municipalities, co-ops, and publicly owned utilities, not just private companies. The Republicans have generally opposed municipal broadband projects, although there are some exceptions in rural areas where local and state officials share the frustration of bypassed local residents.

Manchin

“If you actually get out to Trump country and talk to folks, you will discover that they are angry and frustrated and pissed off that the companies won’t serve them (because it is too expensive to provide service) and won’t let them deploy their own networks,” wrote Harold Feld, senior vice president at the consumer advocacy group Public Knowledge, in a Facebook post this week. “Traditionally, rural Republicans have been eager to use the tools of government to bring essential services to rural America. If this helps pressure rural Republicans to break with the anti-government mantra and return to traditional bipartisan approaches to bringing service to rural America, so much the better.”

Moderate Democrats in states with large rural populations are especially excited by the Democratic plan.

“The way we speak in plain-speaking West Virginia, this is a really good deal,” said Sen. Joe Manchin III (D-W.V.) at a news conference Thursday. “All of you who’ve come from urban areas, you take this for granted.”

The rural broadband funding is part of a much larger $1 trillion investment package paid for by reversing certain tax breaks. The corporate tax rate, which was slashed from 35 percent to 21 percent under the Republican plan, would be raised to 25 percent under the Democratic plan. Democrats are also seeking to restore estate taxes on couples earning over $11 million annually.

President Donald Trump took credit on Friday for Charter Communications’ commitment to hire 20,000 new employees and invest $25 billion on improving cable and broadband service, despite the fact Charter promised to hire those workers more than a year before Trump won the election and its spending commitment may actually represent a reduction in spending.

Today, I was thrilled to announce a commitment of $25 BILLION & 20K AMERICAN JOBS over the next 4 years. THANK YOU Charter Communications! pic.twitter.com/PLxUmXVl0h

— Donald J. Trump (@realDonaldTrump) March 24, 2017

“We are really in the process of announcements and you’re going to see thousands and thousands and thousands of jobs and companies and everything coming back into our country,” Trump told reporters in the Oval Office after meeting with Charter CEO Thomas Rutledge and Texas Gov. Greg Abbott. “They’re coming in far faster than even I had projected.”

Rutledge claimed the company’s promise to spend $25 billion over the next four years was because of Trump’s commitment to cut corporate taxes and further deregulate the cable industry. Rutledge added that he was excited that the time was right in the “regulatory climate and the right tax climate to make major infrastructure investments.”

Unfortunately for both the president and Charter’s CEO, public filings required by the Securities and Exchange Commission show Rutledge’s spending commitment to the president actually could represent a $4 billion reduction in spending over the next four years.

In 2015, Charter, Time Warner Cable, and Bright House collectively spent a combined $7 billion as Charter continued its speed improvements and Time Warner Cable invested in its Time Warner Cable Maxx upgrade initiative. That spending increased in 2016 to $7.1 billion (a figure that excludes merger-related expenses), an amount confirmed in last month’s 4th quarter 2016 financial results:

“Capital expenditures totaled $1.89 billion in the fourth quarter, including $187 million of transition spend,” reported Christopher Winfrey, chief financial officer of Charter Communications. “Excluding transition CapEx, fourth quarter CapEx declined by $81 million year-over-year or 4.5% with tradeoffs between all-digital in the fourth quarter of 2015 in Spectrum pricing and packaging box placement in Q4 2016. For the full-year 2016, our capital expenditures totaled $7.5 billion or $7.1 billion when excluding transition spending.”

Hal Singer, a principal at Economists, Inc., noted Rutledge’s new $25 billion spending commitment could represent a net decrease in spending. That’s because “New Charter” would have spent $28.4 billion over the next four years if it kept combined spending in line with the figures the three companies independently reported in 2015 and 2016.

Rutledge

Charter officials told Ars Technica the spending commitment announced Friday was “specific to broadband infrastructure and technology investment” and claimed it was different from the total capital expenditure figure. Charter claimed spending related to infrastructure and technology was $5.3 billion in annual spending over the last three years, but Charter declined to provide numbers for 2016. It also wouldn’t provide a breakdown adequate to determine if Rutledge’s commitment would result in a spending increase or decrease.

CFO Winfrey told investors in February that a “bigger portion of CapEx” spending in 2017 won’t be for broadband enhancements and expansion, as Mr. Rutledge seemed to tell President Trump. Instead, Charter will spend the money on set-top boxes, cable modems, and network gateways Charter will place in customer homes as a result of an ongoing digital transition, expected to last until 2020.

“When we do an install under Spectrum pricing and packaging, there’s a higher number of devices that we’re placing in the home because of our two-way set-top box strategy as well as our strategy not to charge for modem rental and to have reasonable router fees, which means that you’re going to put more capital into the home on an average transaction and we expect to have [more transactions as a result of increased sales],” Winfrey told investors last month.

Rutledge himself told investors on February’s investor conference call that predicting Charter’s CapEx spending in the future represented an “artificial target.”

“On CapEx, we are not providing CapEx guidance just because we approved a budget internally, which is what we want to operationally deploy this year,” Rutledge explained. “It could be less than that just because of what practically can be done or could be in a position to accelerate. But from our perspective, it doesn’t make sense to release such an artificial target and have the tail try to wag the dog for what’s ultimately right.”

Rutledge agreed with Winfrey’s assessment about what Charter’s spending priorities will be this year: installing more cable boxes and converting customers to all-digital television service. In all, there will be no significant boost in CapEx spending.

“If you think back to what I said, in 2017 we will be spending more on Spectrum pricing and packaging through that higher [cable equipment] placement or connect,” Rutledge said. “We will restart all-digital. We will be insourcing. But offsetting some of that increase will be the benefit of synergies. So without giving specific guidance, 2017 is probably a bit higher in terms of absolute dollars than what we were performing in 2016, but it shouldn’t be a dramatic change in terms of capital intensity or CapEx as a percentage of revenue.”

As for Trump claiming credit for Charter’s commitment to hire 20,000 additional employees, that has been part of Charter’s list of claimed “deal benefits” to win approval of its acquisition of Time Warner Cable and Bright House Networks for at least a year before the election, as Fortune reminds us:

The 20,000 jobs, at least, have been in the works for more than a year. Charter CEO Tom Rutledge said in 2015 that Charter would need to bring on 20,000 additional workers if the company’s merger with Time Warner Cable and acquisition of Bright House Networks went through. A Charter spokesman reiterated the claim in April 2016. The FCC approved the deal last May, and Charter CEO Tom Rutledge said in January that the company had plans to hire 20,000 new employees within three years.

At least 54,000 Time Warner Cable customers downgraded or canceled their cable TV service in the last three months as Charter Communications continues to take a harder line on offering or renewing customer retention discounts for customers unhappy with their bill.

Time Warner Cable customers are “mispriced” with discounts and deals that lower the cost of service but face bill shock when the promotion ends, according to Charter CEO Thomas Rutledge.

“Third quarter customer results were more inconsistent with good performance at Legacy Charter and Bright House, but higher churn and downgrades in the Time Warner Cable markets, as we expected, given the way Time Warner Cable had marketed promotional pricing,” said Rutledge. “Until our Spectrum pricing and packaging is launched across the newly acquired service areas, we continue to expect higher levels of churn and downgrades where Time Warner Cable was the operator.”

“Over the next few quarters, our operating results will reflect reversing certain product and packaging strategies, in particular at TWC, in which in our view are not sustainable, given high promotional roll-offs and annual rate increases, high customer equipment fees, including modem fees, all coupled with complex and stacked offers,” added Charter’s chief financial officer Christopher Winfrey.

Traditionally, Time Warner Cable has dealt with price sensitive customers rolling off special pricing promotions by gradually resetting rates higher or, when necessary, by renewing the promotion for another year in an effort not to lose the customer. That will stop under Charter’s ownership, according to Mr. Rutledge. As a result, Charter Communications is seeing significant customer losses at Time Warner Cable when customer service representatives won’t budge on pricing.

Rutledge is seeking more discipline in product pricing so Charter does not have to extend cut-rate retention promotions to customers. As part of the Charter Spectrum rebrand, the cable company introduces new cable, broadband, and phone plans while allowing Time Warner Cable’s legacy plans to stay in effect until a customer elects to switch. While Texas and California Time Warner Cable customers have already been introduced to Spectrum plans, much of the rest of the country is still being offered plans only from Time Warner Cable or Bright House.

Rutledge

Customers are most likely to cancel service as their promotion expires. The resulting price hike can be a considerable shock as rates quickly reset to Bright House or Time Warner’s “regular price.”

Charter wants an incentive to get customers to forfeit their Time Warner or Bright House plan and switch to a new Spectrum plan as they are introduced. By making the grandfathered plans as unattractive as possible, the alternative Spectrum plans appear to be a better deal. Unfortunately, until Spectrum-branded plans arrive nationwide, many customers are stuck in limbo rolling off a promotion, are unable to renew it, and forced to wait for new Spectrum plans to be introduced.

Rutledge announced last week that the next markets to be introduced to Spectrum this month are in New York City and Florida, the latter former Bright House territory. Rutledge predicted half of Time Warner Cable customers will be offered Spectrum plans by the end of this year. But some Time Warner Cable customers may have to wait until next spring before Spectrum rebranding is complete.

Time Warner Cable Maxx is Still Dead, Earning Charter $36 Million in Reduced CapEx

Charter also reported significant financial benefits from prematurely terminating the Time Warner Cable Maxx upgrade effort. Time Warner’s upgrades would have given customers free speed upgrades up to 300Mbps. But Charter pulled the plug on the upgrade project just after completing its acquisition, and has no plans to restart it.

“Cost to service customers declined by about 2% despite overall customer growth of 5.1%, which reflects lower service transactions at Legacy Charter, the lack of all-digital activity at TWC this quarter versus last year’s third quarter, and some benefit from less physical disconnects in all-digital markets,” reported Winfrey. “Capital expenditures totaled $1.75 billion, including $109 million of transition spend. Excluding transition CapEx, our third quarter CapEx was down by $36 million year-over-year, about 2%, driven by all-digital spending at TWC, primarily on [equipment], which did not recur in the third quarter of this year.”

Winfrey

Charter expects to increase CapEx next spring, as the company continues its less ambitious transition to all-digital cable service, which includes broadband speeds topping out at 100Mbps, three times less than what Time Warner Cable was implementing.

Charter is Less Enthusiastic About Digital Phone Service

Time Warner Cable maintained a healthy market share for its digital phone service by bundling it at a promotional price of $10 a month, a rate that remained relatively stable for customers sticking with a triple play package bundle. Time Warner Cable also enhanced its phone service by adding the European Union nations, Mexico, and several popular Asian calling destinations as part of the local calling area, making those calls free of charge.

Charter’s own plan is less feature-rich and customers have to buy an add-on plan to cover international long distance, making the product considerably less attractive to customers. Some customers also find the cost of the phone service has increased under Spectrum, a problem acknowledged by Winfrey, who noted Time Warner Cable’s low-price voice offer in prior year quarters had been discontinued, resulting in higher voice downgrades and relationship churn.

Charter’s Plans for Legacy Charter Customers and Newly-Adopted Time Warner Cable and Bright House Customers

Rutledge made clear that despite any product changes or rebranding, the long term goal of Charter Communications is to see revenue grow. Whether that will come from gradual repricing of cable products and services to a higher rate or from improved products and services that attract new upgrade business is not yet certain. But Rutledge outlined key areas Charter expects to focus on in the next few years:

• Charter will complete the all-digital transition at Time Warner Cable and Bright House over the next two years, but it will resemble the kind of service legacy Charter customers get today, not TWC Maxx;
• Over the next five years or so, with relatively small infrastructure investments, Charter plans to implement DOCSIS 3.1 which will be able to deliver symmetrical multi-gigabit speeds to all 50 million homes and businesses in their service area;
• Charter plans to aggressively market and grow its services for commercial customers, targeting businesses large and small, at prices that more closely resemble residential service pricing, instead of the price premium Time Warner Cable has traditionally charged its commercial customers;
• Charter is activating its MVNO agreement with Verizon, which will allow Charter to create and market its own wireless/cellular service using Verizon’s nationwide network. The company is also exploring using millimeter-wave (5G) service to offer better broadband coverage in large commercial spaces like malls and rural properties currently not wired for cable service. Expect the company to create its own wireless/cellular bundle first, because it will rely entirely on Verizon’s network, keeping Charter’s costs low.

If the Federal Communications Commission weighed comments for and against the merger of Charter-Time Warner Cable-Bright House Networks based on volume, it would likely be a done deal.

A major lobbying effort by the cable companies involved in the transaction has been underway to encourage politicians, business associations, non-profit groups, and programmers to write the FCC asking the deal be approved. Many are responding, including politicians receiving political donations and/or seeking expanded service for their communities, non-profits that depend on financial contributions from one or more of the companies involved, programmers that live or die based on winning carriage agreements with Charter, Bright House, and Time Warner Cable, and other groups with missions that seem miles away from a multi-billion dollar cable merger.

Stop the Cap! examined many of these curious letters of support. What, for instance, might motivate the New York Snowmobile Association to navigate the cumbersome comment filing systems of both the New York Public Service Commission and the Federal Communications Commission to express glowing support for a cable merger?

The International Soap Box Derby is all-in on the merger of Charter-TWC-Bright House.

What made the Maccabi World Union, the largest Jewish sports organization in the world, enthusiastic enough to dwell on a marriage of three cable companies?

How could the Montana Stockgrowers Association set aside their interest in helping state cattle ranchers to deliver safe and wholesome beef to American dinner tables to ponder modem fees in their letter to the Commission?

One Los Angeles non-profit organization contacted by Stop the Cap! shed some light on the subject, if we agreed to keep their name private.

“Like many non-profits, when Time Warner Cable makes a financial contribution to our organization, they attempt to find ways where both our organization and their company can benefit from goodwill generated by charitable contributions,” the director told Stop the Cap! “When the deal with Charter and Time Warner was announced, we received a gently worded request to participate in the public discussion about the merger.”

The group received information containing talking points about the deal’s benefits to consumers and businesses and was asked to consider using those points in a letter to state and federal regulators that would present a positive view of the deal.

“Non-profits need the contributions of large companies like Time Warner Cable and Charter, which both serve parts of Los Angeles County, to fund our programs,” the director said. “There isn’t any pressure on us to write the letters, but since they are in the public record, we know the cable companies know who wrote and who did not.”

The director of this particular organization had qualms about getting involved in a regulatory matter that did not involve the organization he leads, but he was overruled by his board of directors.

“Money is tight,” the director added. “I don’t want to comment on Charter Cable’s performance in Los Angeles except to say it is the main reason I use someone else.”

The director of the group would not comment when asked if it was uncomfortable signing a letter in support of a company who has failed to meet their personal expectations.

The fact non-profit groups spend time and resources writing letters on behalf of their donors bothers others as well.

Shawn Sheridan of Turlock, Calif. exhaustively researched over 250 pieces of correspondence the FCC has received in favor of the Charter acquisition, and he is not happy about what he found.

“The current public comments process has been infiltrated to purposely influence the independent review process,” Sheridan writes in a letter to the FCC. “I suggest to the Commission that conducting an independent analysis of the comments received from the public for [this merger] would reveal a nationwide campaign to improperly affect the Commission’s independent review of the applications, and reveal unique characteristics of who has and has not commented publicly.”

Sheridan categorized all the letters arriving from state/local representatives, Chamber of Commerce chapters, and non-profit groups:

Letters from different chapters of the Chambers of Commerce, which typically count Time Warner Cable, Charter Communications, and/or Bright House Networks as dues-paying members, were oddly uniform in their praise of the transaction.

The Minnesota Chamber of Commerce, for example, didn’t seem too interested in getting into the specifics of the deal, satisfied instead to request “the FCC approve all matters related to this merger promptly.”

Dozens of other chapters of the business association used similar language praising the merger proposal. Notice the references to “$2.5 billion” promised to be spent on commercial fiber optics and “one million new residential lines” mentioned in a handful of the filings with the FCC:

The Minnesota Chamber of Commerce advocates giving Charter whatever it wants.

• “The Missoula Area Chamber of Commerce is the voice of business in Missoula County….We are excited by New Charter’s commitment to invest $2.5 billion into networks in commercial areas.”
• “As a member-driven organization, the Montana Chamber of Commerce represents the interests of business, ranging from small mom-and-pop operations to large companies….The new company would commit $2.5 billion to the commercial sector and would build out residential lines, improving both industry competition and local infrastructure.”
• “With nearly 700 members that employ more than 12,000 people, the Fremont Chamber of Commerce represents a vibrant, regional business community in eastern Nebraska….Specifically, we are told, the greater financial strength of the unified operations would lead to investment of at least $2.5 billion to upgrade commercial lines to fiber-optics….Therefore, based on their assurances to us, we believe New Charter would be a great partner….”
• “The Florida Chamber of Commerce is pleased to support Bright House Network’s merger with Charter Communications and Time Warner Cable into New Charter….New Charter would be committed to infrastructure investment. It would devote at least $2.5 billion towards commercial networks, contributing important upgrades and competition into this influential market.”
• [Clearwater Regional Chamber of Commerce:] “We understand that New Charter plans to invest $2.5 billion toward commercial networks, contributing important upgrades and competition
• into this influential market and to provide substantial investment throughout the entire State.”
• [Lakeland Area Chamber of Commerce:] “For example, New Charter has committed to $2.5 billion in commercial networks and would build out one million residential line extensions.”
• [San Diego Regional Chamber of Commerce:] “The proposal promises to bring in at least $2.5 billion in new commercial infrastructure investment, much of which will be invested in areas
  where the Charter Communications currently does not operate.”
• “With more than 10,000 members, the Greater Cleveland Partnership (GCP) is a membership association of Northeast Ohio companies and organizations and one of the largest metropolitan
  chambers of commerce in the nation….Specifically, it would commit at least $2.5 billion to build out commercial network lines and put up one million new residential lines….”
• “The Buffalo Niagara Partnership is the region’s private sector economic development organization and regional chamber of commerce….In the near future, our state will benefit from
  a $2.5 billion expansion in the build-out of networks into commercial sectors.”
• “At the Finger Lakes Chamber of Commerce, we serve as the voice of our local business community….We have [been] made aware of a major change in the cable broadband industry. The potential merger of Charter Communications, Time Warner Cable, and Bright House Networks into New Charter….”

The language that implies these are not spontaneous, coincidental pieces of correspondence was couched using phrases like, “we are told,” “we understand,” and “we have [been] made aware.”

These talking points actually originate from Charter Communications’ Resource Center, which distributes pro-merger information to organizations in Time Warner Cable and Bright House Networks’ service areas. The references to $2.5 billion for commercial upgrades and line extensions to one million new residential customers originate in documents like this, tailored in this case to New Yorkers.

Some organizations devote more time to customizing their correspondence than others. The Business Council of New York State and the Orange County Partnership couldn’t be bothered, and essentially cut and paste nearly identical language in their “individual” letters of support:

“We recognize that the information and communications sector is an increasingly critical component of a healthy economy….The Business Council understands that access to a reliable 21st Century communications infrastructure—with competitive options for service—is essential for New Yorkers in their homes, schools and workplaces.“

“The Partnership recognizes that the information and communication sector is an increasingly critical component of a healthy economy….We also understand that access to reliable 21st Century communications infrastructure, with competitive options for service, is a necessity for Orange County residents in their homes, schools and workplaces.“

…and the chances of a multibillion dollar cable merger winning regulatory approval.

Dominic J. Jacangelo was so nice, he liked Charter Communications’ merger twice — once on the letterhead of the New York Snowmobile Association, where he serves as executive director, and in a nearly identical letter signed by Jacangelo as Supervisor of the Town of Poestenkill, N.Y. He cited the same talking points the various Chambers of Commerce did.

Representing the interests of 2.5 million people worldwide or its member Time Warner Cable?

Sheridan disputes how merger supporters often attempt to give their views more weight by implying their positions are shared by their constituents. The Orange County Business Council claimed in its letter it represented nearly 300 Southern California businesses employing over 250,000 in the region and more than two million globally. Sheridan doubts more than 2.25 million people, many working outside the country, support the cable merger as much as OCBC suggests.

A larger question is what motivates the letter writers to weigh in on a cable merger in the first place?

For the ranchers in Montana, the desire for more rural broadband is well known. Cable operators usually don’t provide service to large, expansive ranches where a herd of cattle often vastly outnumbers the local population.

For Mr. Jacangelo, his LinkedIn page cites his talents for developing “professional relationships with business sponsors and [supporters], which might be helpful as the town of Poestenkill, like many other rural communities in upstate New York, seek expanded broadband service.

In 2009, the Maccabi World Union partnered with Jewish Life Television to provide in-depth coverage of the Maccabiah Games, a global sporting event. U.S. viewers see coverage of those games over Jewish Life TV, a cable network that reaches Time Warner Cable and Bright House customers, but not Charter Cable customers. A takeover of Time Warner and Bright House by Charter Communications could risk the end of that carriage agreement. Supporting Charter at its time of need may establish enough goodwill to guarantee JLTV will be a part of the “New Charter” lineup.

Sheridan’s research also discovered, as of Oct. 9, 2015:

• With a total of 31 letters from politicians in the state of Texas, not one came from a local official. Eighteen Chambers of Commerce in Texas sent letters in support of the deal;
• No state-level representatives weighed in on the deal in New York either, although 30 local and county leaders gave their support;
• One third of the 28 states where Charter provides service had no comment on the merger, pro or con, hardly representing a nationwide groundswell of support;
• Charter Communications’ corporate headquarters, formerly in Missouri and now in Connecticut, also drew little hometown interest. Just one letter from a state-level politician in Missouri reached the FCC. There were no letters from Connecticut at all;
• Of 258 unique commenters sending letters in support of the merger, 211 (82%) claimed to represent the interests of their members and affiliates without providing supporting evidence that was true. Most of those organizations received direct financial support or in-kind contributions from one or more of the involved cable operators or counted them as dues-paying members;
• Not counting Time Warner Cable or Bright House’s combined 13+ million customers, only about 30 unique consumers submitted a comment to the FCC regarding the merger, representing 0.000005% of Charter’s six million customers.