Companies like to pretend that mergers are about more than consolidating power and increasing profits. To push massive mergers through, they make a whole host of promises and spend a whole lot of money spinning stories that makes it sound like their deals will be in the public interest — ­and in the best interests of marginalized communities.

But this is rarely, if ever, the case.

Broadband and cable providers in particular have tried to appeal to communities of color by promising to increase diversity in programming. These companies also vow to make broadband more affordable for low-income households.

The most recent example of this dynamic is Charter Communications.

Charter, which is trying to take over Time Warner Cable, just signed a Memorandum of Understanding (MOU) with several prominent civil rights groups. In the MOU, Charter pledges to, among other things, “expand programming targeting diverse audiences.”

On paper, such commitments may appear to benefit communities of color. But as a report from Columbia University’s Center for the Study of Ethnicity and Race shows, there’s good reason to be skeptical about whether Charter will follow through.

“The Latino Disconnect: The Impact of Media Mergers on Latino Consumers and Representation” found there was “no significant increase in diversity behind the camera after the 2011 Comcast-NBCUniversal merger, despite a pledge to increase Latino representation in programming.”

The study examines media mergers that have taken place since 2008 but takes a deeper look at the Comcast deal and focuses specifically on Latin@ representation. The research shows that while Latin@ representation went up slightly in front of the camera following the merger, representation actually declined behind the camera. And overall, “the agreements and promises made before the merger weren’t really panning out.”

And despite the pledges from companies like Charter to make broadband more affordable, a recent Pew study found that broadband adoption rates for Black and Latin@ households have dropped significantly over the past two years due to the high cost of broadband.

Unfortunately, the promises these companies make to civil rights organizations and the communities these groups represent are unenforceable. Meanwhile, communities of color would suffer most from the Charter merger, which would lead to higher prices for cable and broadband.

Many groups have come out against the takeover for this very reason. The National Hispanic Media Coalition recently filed testimony with the California Public Utilities Commission opposing the merger. NHMC President Alex Nogales noted that “a merger of this size and scope would grant an unacceptable concentration of power over the cost and quality of broadband connections and access to diverse programming … this merger would be a bad deal for Latinos and California.”

Meanwhile, Presente.org, the nation’s largest Latin@ online advocacy organization, also opposes the merger, stating it would hit the Latin@ community and other underserved populations hard with steeper prices and poorer service.

Companies like Charter and Comcast make promises around diversity to win support for their mergers because they know how important issues of access and representation are to communities of color. They also know there are no real ways for us to hold them accountable.

All communities of color deserve the opportunity to tell their own stories, find adequate representation on every channel and have access to affordable broadband services. But history has shown us that companies like Charter will exploit the marginalization of our communities to get what they want. And as the Columbia study has found, these merger-related promises often go unfulfilled.

Join Free Press in urging the FCC to stop the Charter-Time Warner Cable merger.

Lucia Martínez is an organizer for Free Press’ campaign initiatives.

Editor’s Note: In the Spanish language most (not all) nouns are assigned gender—masculine or feminine. To promote gender equality/gender neutrality, many prefer to use the term “Latin@,” which refers to both men (latino) and women (latina). (The “@” symbol encompasses both the “a” and the “o.”)

More than a dozen industry-supported non-profit groups turned out in force at last evening’s public hearing in Los Angeles run by the California Public Utilities Commission to ask the regulator to approve the merger of Charter Communications and Time Warner Cable.

But one deal supporter also used the occasion to attack consumer advocacy groups lined up to oppose the deal, without apparently mentioning the fact her group Smart Education counts Time Warner Cable as a major sponsor of the organization.

Liberty Naud told the audience the merger would help California improve its math and science scores and help educate the next generation of entertainment industry employees.

“Last year, the United States was ranked 27th in math, and 28th in science among 34 developed countries,” said Naud, whose group serves the Coachella Valley. “By 2018, we are going to be short 3 million science, technology, engineering and math jobs. How many of our at-risk youth could fill those spots if they had the access that they needed?”

The Los Angeles Times reports Naud took a jab at the consumer advocacy groups and a representative of the Writers Guild of America, West, who opposed the deal.

“Who brings those stories you write to life? Who does the editing and creates the equipment that makes it possible to film those ideas?” Naud said. “Technologists, engineers and sound scientists.  We don’t just need this merger, it is a necessity.”

Stop the Cap! believes you don’t need a math degree to calculate conflict-of-interest. It has been our experience that what often motivates non-profit groups to appear at an obscure hearing in support of a multi-billion dollar cable merger is money. Those financial relationships should always be disclosed at public hearings and in media reports to give the public important context.

It will also come as no surprise we believe Naud’s argument in nonsensical. Should this merger not be approved, Charter and Time Warner Cable will continue to offer service in their respective areas. Charter is proposing new Internet programs for the income-challenged and Time Warner Cable already offers a $14.99 Internet plan open to anyone. Both cable companies set their own policies about rural access, pricing, and discounts to at-risk communities. A merger is not necessary to provoke change.

Californians will have their chance to speak out about the proposed merger of Charter Communications and Time Warner Cable at a public hearing in Los Angeles tonight before an administrative law judge working for the California Public Utilities Commission (CPUC).

California will be the last major state capable of killing the transaction should the CPUC reject the merger on the grounds of it not being in the public interest. New York regulators approved the merger, but only with a lengthy list of conditions designed to improve service for New York residents.

Stop the Cap! will be represented at the hearing tonight by Matt Friedman, who will help us improve our vigilance of cable and phone companies serving the west coast. Friedman has done an incredible job exposing the sham of usage caps and compulsory usage-based pricing in his written testimony, which will be published here after being filed with the CPUC. As with most CPUC public hearings, we expect speakers will only be given a few minutes at most to state their views on the merger. As we did in New York, Stop the Cap! will oppose it on the grounds it is not in the public interest.

We remain suspicious about Charter’s commitment to not impose usage caps or usage pricing for only three years. Most consumers will not see much of a change in the broadband marketplace over the next few years. Charter can afford to wait 36 short months before potentially slapping on usage caps/billing — after winning additional regulatory approval to buy out even more companies. While the CEO of Time Warner Cable will walk away with over $100 million in golden parachute benefits if he successfully sells Time Warner Cable, we anticipate most customers will win a higher bill.

Friedman will share our ongoing concerns that Charter’s offer is less impressive than Time Warner Cable’s own Maxx upgrade initiative, which will deliver 300Mbps service for the price Time Warner Cable customers currently pay for 50Mbps. Time Warner Cable’s $14.99 budget Internet service is also on Charter’s chopping block, to be replaced with an entry-level tier offering 60Mbps for about $60 a month — four times more expensive. In short, the only honest reason to allow this deal to succeed is if we want to further enrich Time Warner Cable executives and shareholders while customers take all the risks of higher bills, worse service, and usage caps starting in 2019, with few if any other options.

Also planning to attend are Common Cause, Free Press, and the National Hispanic Media Coalition, which all argue allowing this deal to succeed sets up America for a national virtual duopoly between Comcast and Charter, with just two companies controlling the majority of broadband connections in the United States.

The CPUC could reject the merger outright or approve it, usually with conditions. While we remain opposed to the merger, should the CPUC ultimately make a different decision, we are advocating:

• A ban on compulsory usage caps or usage pricing. An affordable, unlimited option broadband tier should always be available, at prices comparable to what consumers pay today for Internet service.
• Charter should be forced to commit to upgrading its entire service area in California to an equal level of service offered by Time Warner Cable Maxx.
• Charter should be required to keep Time Warner Cable’s affordable, no-contract/no-requirement $14.99 Everyday Low Price Internet plan and boost its speed.
• Most-favored state status for California, automatically giving California consumers the benefits won from conditions imposed by regulators in other states.
• …and other consumer-targeted service improvements.

If you are in Los Angeles and want to attend or possibly share your own views with the CPUC, the hearing is open to the public:

Location: Junipero Serra State Office Building – Auditorium (Carmel Room)  — 320 West 4th Street, Los Angeles
Time: The meeting starts at 6:00pm

A behind the scenes struggle between DISH Networks and Charter Communications over DISH’s online video service Sling TV has led to an admission by a Wall Street analyst that “usage-based billing” is an important tool for stifling over-the-top online video competition.

On Dec. 21, DISH’s legal team sent a letter to the FCC complaining about Charter’s attempts to “address” the competitive threat of Sling TV, DISH’s online video alternative to cable television.

“Charter’s laser-like focus on Sling TV shows that it views Sling TV as a serious competitive threat rather than a benign interest,” wrote DISH’s attorneys. “Charter is focused on protecting its video subscriber base rather than enhancing the broadband Internet experience for its subscribers. Charter’s documents further reveal thinly veiled complaints to programmers about making their programming available to Sling TV and other [online video] products.”

In the highly redacted filing, Dish suggested Charter was making thinly veiled threats to Disney and Scripps Networks over their willingness to allow their content to be included on Sling TV. DISH has complained to the FCC the cable company was attempting to undermine the new competitor.

On Thursday, the FCC also received an ex parte filing alerting the public that Time Warner (Entertainment) and HBO executives privately met with FCC staff last week, at their invitation, telling them Charter was likely threatening other programmers with unspecified action if they continued to allow their programming to appear on Sling TV.

In that meeting, HBO executives suggested “New Charter” — the combination of Charter Cable, Time Warner Cable, and Bright House Networks — “would be inclined to take action directed at programmers” if services like Sling TV continued to grow. Those threats seem to have been confirmed by Charter CEO Thomas Rutledge, who warned the company would take ‘competitive action’ against programmers selling content to the competition.

In the past, several cable executives have hinted that allowing wider distribution of cable networks over competitors’ networks or direct-to-consumer would dilute the value of those networks to cable operators. That would likely lead to demands for reduced prices when cable networks sought contract renewal. Some cable companies might also drop those networks altogether, arguing customers can get them elsewhere. Either retaliatory move would cut viewer numbers, which in turn would force networks to charge less for advertising.

That the FCC would invite further discussions on the issue of online video competition has some on Wall Street concerned about the prospects of Charter winning approval to buy Time Warner Cable and Bright House.

On Friday, BTIG analyst Richard Greenfield wrote investors, wondering if “we should be less confident in deal approval than we currently are.” With both the Justice Department and the Obama Administration pushing hard for competitive online alternatives to cable television, the FCC may be worried allowing New Charter to have 25-30 percent of the broadband market. With broadband a prerequisite for signing up for services like Sling TV, Rutledge’s “competitive action” could dissuade consumers from choosing online video instead of cable television.

New Street Research analyst Jonathan Chaplin admitted one of Charter’s strongest potential weapons against online video competitors is usage-based Internet billing. That Charter has committed to avoiding usage pricing for the next three years would seem to delay any attempt by Charter to deploy usage caps and usage pricing to stop online competition.

But three years may also not be long to wait, especially if the current “cap-free” commitment helps win merger approval. Chaplin believes Charter’s current commitment to not impose usage caps weakens DISH’s argument, but it could be the subject of special conditions from regulators if the deal is ultimately approved.

The topic appears to be sensitive enough to have provoked Charter to push back hard against DISH and Time Warner (Entertainment) in a blog post published last Friday afternoon.

We are happy to report that the vast majority of stakeholders are pleased with the merger and excited about New Charter.  It’s no surprise, though, that there are some who seek to use the regulatory review process to extract concessions or conditions that further their business goals.  Following the well-worn play book, to achieve that goal, they must first try to discredit the merger, but their allegations are often not based on the facts. For example, charges by Dish and Time Warner’s HBO that New Charter will harm Online Video Distributors simply do not make sense. As we have demonstrated, there is no more OVD-friendly provider than Charter, with our slowest speed at 60Mbps, no data caps, no usage-based billing, no annual contracts and no modem fees. Additionally, we’ve committed that New Charter will offering settlement-free peering to Internet companies, which means we will continue to invest in interconnection to avoid congestion. Netflix CEO Reed Hastings, a supporter of the transaction, stated “the key thing about the Charter deal is it’s all Internet companies that benefit — us, Hulu, Amazon, HBO Now — so that we can all compete for consumers’ affection.”

Conditions recommended by Stop the Cap! to protect New York consumers after a merger of Charter Communications and Time Warner Cable are expected to cost the two cable companies almost one billion dollars and will guarantee statewide adoption of Time Warner Cable’s Maxx upgrade, guaranteeing all customers receive speed upgrades ranging from 60-300Mbps.

On Friday, the N.Y. Public Service Commission announced its conditional approval of the merger transaction, but only if Charter agrees to a series of wide-ranging conditions to guarantee that New York customers receive tangible benefits as a result of the merger:

The Commission agrees that in order for the proposed merger to be in the public interest, the Petitioners must agree to make concrete and enforceable commitments to modernize their cable system and services, expand access, address the digital divide and improve customer service. To this end, we find that with the acceptance by the Petitioners of the enforceable conditions, as discussed in the body of this Order and Appendix A, the proposed merger is in the public interest. These conditions are designed to help ensure a near ubiquitous world-class communications network that meets the needs of all New Yorkers. Absent acceptance of these conditions, the public interest standard cannot be met, and the petition for transaction approval is denied.

Stop the Cap! was quoted and footnoted extensively in the PSC order. We provided the PSC with insight beyond the public relations machine of Charter and Time Warner Cable. We exposed the fact Charter’s promised service improvements were actually more modest than what Time Warner Cable has undertaken on its own through its Maxx upgrade program. We educated regulators about the inadequacy of Charter’s initial commitment to offer low-cost Internet access for low-income families. We questioned the consumer benefits of certain upgrades that could actually increase costs for consumers because of additional equipment fees. We alerted the PSC that Charter would discontinue Time Warner’s affordable $14.99 Internet offer. We strongly recommended the PSC consider making rural broadband expansion a part of this transaction. We also sought additional protections from any future compulsory usage caps or usage-based billing.

Although Stop the Cap! was opposed to the transaction from the outset, doubting it was in the public interest, we recognized the chances for approval were greater than the Comcast-TWC merger that was eventually withdrawn. Therefore, we made it a priority to outline multiple conditions we felt should be imposed on Charter if the deal was to be approved.

Our constituency is ordinary consumers and ratepayers. Too often these kinds of mergers are approved with token conditions that only benefit minority or special interests, favored non-profit or government entities, or those with vested business interests (programmers, equipment manufacturers, etc.) It was important to us that any approval bring something beyond free Internet service for schools or community centers, agreements to continue carrying certain cable networks, or a temporary discount or low value coupon that ends up in the mailboxes of customers a year or two from now.

We know what Time Warner Cable customers in New York want: better service, faster speeds, no data caps, no gotcha fees, affordable Internet options, and job protection.

It appears New York regulators understand that as well and intend to force Charter to offer customers a better deal.

Despite publicly saying little about the merger, just a few hours after the PSC’s decision, Gov. Andrew Cuomo’s office issued a press release taking credit for the merger conditions and unveiling the “tenth signature proposal of his 2016 agenda: dramatically expanding and improving access to high-speed Internet in communities statewide.” Once again, the governor will try to entice providers like Time Warner Cable, Frontier Communications, and Verizon to expand rural broadband in New York using public dollars.

Although lacking a catchy title, the “New New York Broadband Program” includes a $500 million solicitation for private sector partners to subsidize rural broadband expansion with state dollars. The key goals of the 2016 program include:

Much of the funding from earlier years ended up going to Time Warner Cable for modest expansion of its cable service, especially in eastern upstate New York. Likely applicants in 2016 include Time Warner Cable, Frontier Communications, community-owned/co-op broadband providers and rural wireless ISPs. Verizon and Cablevision are unlikely to apply.

Despite the governor’s efforts, most New York homes and businesses will be more affected by the Charter-Time Warner Cable merger, if it wins federal approval.

The Public Service Commission took its role very seriously, issuing a 93-page decision that took recommendations from consumer groups including Stop the Cap! very seriously. It did not share the industry’s belief that telecommunications providers in New York are heavily competitive.

“Time Warner serves close to 50% of New York State and we have a legitimate interest in ensuring that, when a company of this size provides customers with a service so affected by the public interest, as is communications, that real benefits accrue to consumers as a result of a given transaction,” the PSC wrote.

The PSC had an easier time sorting through comments about this merger, which generated considerably less interest than Comcast’s failed attempt to buy Time Warner.

“Generally, comments supporting the proposed transaction assert that, among other things, the merger will create jobs and provide better products at more affordable rates,” the PSC concluded in its ruling. “Those opposing the transaction state that the merger will inevitably lead to higher rates and potential data caps on broadband services in the future.”

The PSC took a very skeptical approach to Charter’s promised benefits, often finding them vague, questionable, or likely to have occurred with or without Charter’s involvement.

For example, the PSC questioned Charter’s promised network investments and upgrades:

Petitioners, however, decline to specify where in the national footprint of Charter, TWC and BHN these investments will be made or to identify the decisional factors to be used to channel these capital resources to specific areas or customers. There is no analysis to indicate that a reasonable proportion of these investments will be to systems in New York or for the benefit of New York customers. Similarly, there is no proposal by the Petitioners to describe the specific commitments that are being made or the specific enforcement mechanisms that would be used in the event the Petitioners’ implementation fell short of their commitments. Further, in order for these investments to be characterized as part of a net public benefit, Staff concludes, and we agree, that Petitioners would have to establish that these investments would not have been made in the absence of the proposed merger.

In the absence of a demonstration that there is “a tangible commitment to make new investments or invest beyond Time Warner’s current capital investment budgets,” it is difficult to characterize these capital expenditures as a certain benefit to New York customers or a satisfaction of the public interest under the New York statutes.

One of Stop the Cap!’s core arguments in our comments to the PSC was that Charter’s upgrade commitments were not particularly meaningful because Time Warner Cable was gradually upgrading its own systems to a level of service superior to what Charter plans to offer. The PSC clearly understood this and our warning that Charter’s commitments lacked specificity:

Public Benefit Assessment Staff and several commenters suggest that the proposed merger, as described in the Joint Petition and Petitioners’ Reply Comments, does not have sufficient net benefits to warrant a finding that the transaction is in the public interest. We concur. Many of the asserted benefits from the proposed transaction are events triggered by actions taken independently from the merger, and others are likely to be undertaken by TWC in any event, should the merger not be approved. Further, many asserted benefits are only described on a national scale and there is no way to determine if the investments or expenditures will occur in New York. Similarly, many of the projected benefits are described in terms that are too indefinite to permit us to assume that the benefits will occur as described to make a meaningful contribution to the transaction’s net benefits.

As a result, the PSC has looked more closely at Time Warner Cable’s Maxx program to be the benchmark for New York, not Charter’s proposed upgrades. They have adopted our recommendation that every Time Warner Cable customer in New York get the same kind of service upgrade residents in New York City enjoy today.

Another argument made by Stop the Cap! dealt with affordable Internet access. Time Warner Cable’s Everyday Low Price Internet ($14.99/mo for 2Mbps) is not fast, but it is affordable and free of the kind of revenue-protecting pre-conditions usually placed on Internet access for the poor. Time Warner’s plan is available to every customer at any time with no restrictions or contracts. In contrast, Charter’s originally proposed affordable Internet program required participants have school-age children, enroll only in the late summer, not have current cable broadband service (or be willing to forego it for 60 days), and not have any prior balance. As with Comcast, pre-conditions like this limit participation. The PSC agreed and now customers will be able to keep their more affordable Internet plans without jumping through artificial hoops launched by Charter.

The days of rural New Yorkers being quoted $20,000 to install Time Warner Cable service are also going to be a thing of the past. In addition to a commitment to pay for line extensions reaching 145,000 unserved or underserved customers, Charter is now required to work with New York’s Broadband 4 All program to receive supplementary funding, as available, to complete service extensions to eventually reach every customer that lives within a franchise area and wants cable service.

There are several other benefits outlined below that make this a better (although not great) deal, at least for New Yorkers. If any other state regulator manages to get an even better deal for that state’s residents, New Yorkers will automatically benefit because of a “most favored state clause” in the PSC’s order, which requires Charter to share those benefits with New York residents.

All in all, the New York State Public Service Commission has lived up to its reputation as a consumer-protective body that is responsive to the needs of the public. This is in great contrast to many other states where regulators seem themselves as a business facilitator (and occasionally come directly from the businesses being regulated). In these states, the merger won approval with few, in any, preconditions.

We were delighted to have been extensively quoted and footnoted in the PSC’s order, having proven our case the Charter-Time Warner deal didn’t offer very much for New York. But we’re not happy the PSC punted on data caps. While recognizing they are a concern, the PSC seemed satisfied a three-year guarantee of no data caps was adequate. We disagree. As an increasing number of Comcast customers can attest, data caps are anti-competitive, anti-consumer, and unnecessary. Whatever benefits faster speeds can deliver can be easily curtailed by a data cap. So can online video competition. With much of upstate New York totally dependent on a single provider – Time Warner or Charter – for broadband speeds above 10Mbps, there is plenty of room for mischief that would otherwise be controlled by competitive forces. The PSC saw fit to avoid using its power of approval to get creative on keeping flat rate Internet affordable and available. That is a mistake we predict will be back to haunt us in the future.

Here are the specific conditions, most advocated by Stop the Cap!, that Charter Communications must agree to as a condition of the deal’s approval in New York:

Rural Broadband Access [$355 Million Value]

In addition to the goals accomplished by Gov. Cuomo’s New New York Broadband Program, Charter must agree to unilaterally build-out its network to reach an additional 145,000 “unserved” and “underserved” homes and businesses within four years. This will be an easy target for Charter to reach because the PSC defines “underserved” as any home with less than 100Mbps service. That represents much of upstate New York bypassed by TWC Maxx, so a speed upgrade in just one upstate city will achieve this requirement.

However, the PSC also included a second condition. Subject to the final terms and conditions of the Broadband 4 All Program being comparable to the Connect New York Program, Charter will be required to bid for Broadband 4 All Program funding to offer line extensions to any remaining unserved and underserved home across its entire New York service territory, which means every New Yorker within a cable franchise service area that wants service will be able to get it without being quoted tens of thousands of dollars for construction costs.

This will finally help would-be customers like Stop the Cap! reader Jesse Walser in Jamesville who has tried to get wired broadband in his home for over a decade. Verizon won’t upgrade its network and Time Warner Cable quoted him between $5,900 and $26,000 for installation of a line extension to reach his home.

All Digital Cable System Upgrade

Charter must convert their existing New York systems to an all-digital network (including upgrading the Columbia County Charter cable system to enable broadband communications) capable of delivering faster broadband speeds.

In Columbia County, residents are currently better served by smaller local providers. Both Germantown Telephone and Mid-Hudson Cable offer high-speed access throughout their territories. Berkshire Telephone has almost 100% DSL coverage, and Taconic Telephone has expanded DSL service to much of their huge service territory. Frontier Communications offers some DSL in southern Columbia County. The biggest problem providers are Verizon, which has no plans for DSL service in the area, and Charter Cable, which still runs a basic cable television-only system in the county.

In New York, Charter now provides cable television and other communication services to a relatively small number of customers, from two cable system clusters in and around Plattsburgh (14,000 customers) and Columbia County (2,500 customers). Plattsburgh gets television, phone and broadband service from Charter, but Columbia County is still served by a now-ancient, cable television only system.

Network Modernization and Speed Increases [$305 Million Value]

Charter must convert all of its systems in New York to all-digital within 30 months of the closing of the merger transaction. Charter is also required to offer broadband speeds up to 100Mbps to all customers by the end 2018 and match TWC Maxx speeds of 300Mbps by the end of 2019.

Charter’s all digital upgrade in upstate New York will facilitate faster broadband service, but it will also mean a set-top box or other similar device for every cable connected television in the home.

Broadband Affordability [$250 Million Value]

Despite Charter’s simplified menu of options (two broadband speed tiers and one video package), the PSC has required Charter to allow customers to keep their current plans, at least for the next several years:

• Charter is required to maintain and advance its commitment to an affordable standalone Internet offering through the continuation of the Time Warner Everyday Low Price $14.99
  service throughout the Time Warner New York territory for up to two years and allow existing customers to keep the service for three years.
• Charter is required to offer its 60Mbps standalone broadband product throughout New York at uniform national pricing. [$125 million value]
• Charter is required to allow existing Time Warner customers to retain, without material changes that have the intent to discourage, the standalone and bundled broadband services they subscribe to at the close of the transaction for three years from the date of the closing.
• Charter is required to provide a low-income broadband offering to eligible customers throughout its New York footprint. The PSC-ordered plan will offer 30Mbps for $14.99 a month to any household eligible for the National School Lunch Program and senior citizens 65 years and older eligible for the federal Supplemental Security Income program. No credit check shall be required and conditions requiring current broadband customers to wait 60 days to qualify and cover any past due bills have been deleted.

Customer Service [$55 Million Value]

Within two years after the close of the proposed transaction, Charter shall invest a minimum of $50 million in service improvement programs.

Charter is required to show a 35% reduction in Time Warner Cable’s 2014 cable PSC Complaint Rate by the end of 2020, with a 17.5% reduction due by the end of 2018. If they don’t achieve that, Charter must invest an additional $2.5 million in its service for each failure.

Job Protection

For the next four years, Charter cannot cut the number of customer facing jobs in New York.