IRREGULATORS to FCC: Data Caps on Wireless Broadband Harms Low Volume, Low Income and Rural Families.
There is no such thing as ‘unlimited’ mobile 5G broadband services in America, and the chart above shows the limit of data cap on wireless packages offered by the resellers of Verizon, AT&T, or T-Mobile, known as MVNOs.
Never discussed, America has only 3 primary US wireless carriers; almost all of the other large mobile services from TracFone to Cricket, or Spectrum Mobile or Mint Mobile, all rely on these 3 companies.
NOTE: The IRREGULATORS filed comments and supply new research and analysis in the FCC’s new proceeding that examines the application of Data Caps. We call for investigations for the removal of Data Caps and the lowering of prices, including the removal of junk fees.
- FCC Filing 1: IRREGULATORS: COMMENTS AND A CALL FOR INVESTIGATIONS
- FCC Filing 2: SEPARATE REPORT ATTACHED: IRREGULATORS ANALYSIS:
- Supplemental 3: WHAMMING EATS THE MOBILE 5G DATA CAP LIMITS.
What is a Data Cap? It is the limit on the amount of data, commonly called “Gig s” or sometimes referred to as “GB” that a customer purchases on a monthly basis, and after this capacity is used up, the speed of service can go from a 4G or 5G broadband speed, to an unusable crawl, or force the customer to purchase more GIG. This slow-down, known as “throttling”, lasts for a billing cycle.
The chart above shows the number of GB that comes with the service and there are 2 ranges; those with 1–6 GB and the larger group of 20–50 GB. And all priced accordingly.
This means that if you have a service of 2 GB, after this is used, for say streaming a show or a Zoom meeting, the service can be rendered unusable.
But it is the chart below that is most troubling. We use the ACP program results in part because if prices don’t go down, the affordability for millions of low income families will be in jeopardy.
Overseas Prices are Shocking: $8.50 for 100GB vs $4.50 a GB in the ACP Program.
Wireless 5G Broadband Prices Overseas; 8 Euros for 100 GB
Overseas, Rewheel Research has examined the prices for 5G mobile broadband and found that for about $8.50 US, a customer gets 100 GB, or $.08 cents per gig. It also shows that markets with only 3 primary carriers are not competitive and have rates that are out of control. Case in point, the United States is one of the most expensive services in the world. In the chart above, we’re all the way to the left — most expensive, worldwide.
NOTE: The value of the Euro has been fluctuating, and went down to $1.04 for 1 Euro to $1.08 during the creation of this report. This means that the prices would be $8.32 vs $8.64.
Lots of Competitors vs 3 Primary Networks. The US has about 140 resellers, and almost all use one of the 3 carriers. Moreover, the companies have multiple subsidiaries that received ACP funding. AT&T alone had 90+ companies or subsidiaries or affiliates getting ACP funding.
Data Caps on services are just a symptom of an out of control marketplace.
- Whamming — Hidden from sight, customers are paying extra for actions that increase the amount of data used by the customer or is charged for, including ‘network overhead’ or ‘apps’ that are generating updates but are not in use.
- Junk Fees — are taxes, fees and surcharges, and just made up stuff, that is added to the bills, usually as separate line items. They include the ‘cost recovery’ charge, or the taxes and surcharges that are pass-throughs to the customers. These are not government mandated or cost justified.
The ACP low income subsidy for broadband, at $14 billion spent, gave 23 million families an assistance of $30 and it ended in June 2024. This covered about 25% of the recipients, and additional funds were required.
With a price of about $3-$15 per GB in the US at the low end, then capped, more research is needed on the low volume users and low income families and the actual usage of customers.
Data Caps, then, needs to be put into perspective. We didn’t need ACP or data caps if prices in the US were even close to overseas markets, and as we discuss, the core issues need to be addressed moving forward.
However, even if companies start using the other government subsidies to build out their areas, if the pricing isn’t affordable, with competition, America is still going to have to solve this Divide.
The FCC Never Addressed these Issues
The incoming proposed FCC Chairman, now Commissioner Brendan Carr, in his 2024 Net Neutrality ‘dissenting view’ wrote everything is OK.
“And today’s Order is not about correcting a market failure. Broadband access is more vibrant and competitive than ever, no matter how you slice the reams of data. Americans benefited from lower prices, faster speeds, broader and deeper coverage, increased competition, and accelerated Internet builds.
“Here’s what the data show. Internet speeds are up 430% since 2017 on the fixed broadband side, and they are up 647% on the mobile side. In real terms, the prices for Internet services have dropped by about 9% since the beginning of 2018, according to BLS CPI data. On the mobile broadband side alone, real prices have dropped by roughly 18% since 2017, according to BLS and industry data. And for the most popular broadband speed tiers, real prices are down 54%, and for the fastest broadband speed tiers, prices are down 55%, over the past 8 years, according to BLS and industry data.”
Real prices? Prices went down? How can the future proposed FCC chairman claim prices went down and are competitive?
Overseas: $.08 cents per gig in countries with competition vs $4.50 per gig in America, is the reality. And, as we show, there are plenty of other reports not mentioned by the FCC that show prices went up, especially the additions to the junk fees. And while sounding official as a government statistic, the BLS analysis is not based on collecting actual bills, so it has always been at odds with ‘reality’. And using the industry statistics for some areas, like the price of service, never matches actual bills with all of the line items accounted for.
In fact, we filed a complaint in 1994 over the FCC’s data and analysis of phone rates and telecommunications information, which include BLS-CPI analyses. 30 years later and the FCC and the companies are still using basic, but flawed analyses as the agency doesn’t collect actual bills, therefore actual charges, and the ‘nutritional labels’ do not supply the all of the taxes, fees and surcharges for a customer. In short, the FCC’s allows for a deceptive and incomplete analysis of what are the actual charges on actual bills. customers actually pay.
The Data Cap Issue: Netflix and Zoom Usage Requirements, 2024.
Just to put some reality into the question of how much does a person or family need to go online and attend school or just watch a movie, at this point, the rule of thumb is for HD quality a 2 hour movie on Netflix is about 6GB, while a Zoom meeting requires 2.4 GB per hour.
Of course, a user can use Wi-Fi or other data that is not billed the same way, but there are a host of restrictions depending on the service.
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Excerpts from the IRREGULATORS Filing and Report
1) Price of Mobile Wireless Service in the US.
2) Prices have been going up over the last few years.
3) The average/median price per gig overseas and the US.
4) The Data Cap Issue: Netflix and Zoom Usage Requirements, 2024
5) Corporate Propaganda: Industry and FCC Claim Prices are Going Down,
6) Junk Fees are added fees that are hidden from the total advertised price of service.
7) Verizon NY 2023 Annual Report Excerpt. Examining the cross-subsidies using the wireline state utility construction for wireless.
8) The fiber optic wires are put in as part of the state utility as Title II, common carrier networks.
9) Big Foot the AT&T and Verizon “Footprints” Revealed
10) We ask the Commission to investigate these issues now, as part of the data cap proceeding because if our analysis is correct.
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DISCUSSION
1) Price of Mobile Wireless Service in the US.
According to many sources:
- Average Price of Cell Phone Service in Americs; We will use $144.00 a Month.
- J.D. Power: Reports that the average phone bill is $141 per month
- WhistleOut: Average American spends $157 per month on their cell phone plan
- CNBC: Average monthly expense for a cellphone plan is $144.
2) Prices have been going up over the last few years.
There are recent data from other sources that show that rates have increased, not decreased.
US News and World Report claims that prices for internet have gone dramatically up since April 2024. Here’s How Much Internet Costs (Then and Now) in the Most Populous States in America [Survey Report] Oct. 21, 2024.
“The average internet bill at sign-up among the most populous states was $81. That’s a bit higher than what we found in our April 2024 survey report, which showed the average initial internet bill nationwide was $77.
“The average internet bill today among the most populous states is $98, which again is a slight increase over the average current internet bill nationwide of $89 identified in our April 2024 survey report.”
“Rising Internet Costs in New York
§ “The average internet bill for New Yorkers at sign-up was $85.
§ “The average internet bill for New Yorkers today is $99.
“Rising Internet Costs in Pennsylvania
§ The average internet bill for Pennsylvanians at sign-up was $83.
§ The average internet bill for Pennsylvanians today is $110.
These are wireline ISP broadband services, not the wireless voice services, but what is clear is that the phone and cable companies will continually distort the storyline.
Of course, there is the rise in inflation, and the other standards like the Consumer Price Index, with comparisons to prices of service. At the core, prices should be in steep decline because of staff cuts that have been continuous or the write-offs and depreciation of the networks, lowering the value of the networks.
3) The average/median price per GB overseas and the US
NOTE: As discussed, the value of the Euro has been fluctuating, and went down to $1.04 for 1 EURO to $1.08 during the creation of this report. This means that the prices would be $8.32 vs $8.64.
NOTE: There are few if any 100 gig residential mobile wireless broadband services, especially not at this price. We consider FWA Wireless, fixed wireless a different service which is competing with a fiber optic connection or cable wired services.
4) The Data Cap Issue: Netflix and Zoom Usage Requirements, 2024.
- NETFLIX: How many GBs is a 2 hour movie on Netflix? 2 GB to stream a two-hour SD movie, 6 GB to stream the HD version or 14 GB for the 4K stream. A half-hour TV show; 500 MB for the SD; 1.5 GB for the HD; or 3.5 GB 4K.
- ZOOM: How much data does a 2 hour Zoom meeting use?
- “2.4 GB/hr. Your Zoom data usage jumps up with more people on the call. Group Zoom meetings take up somewhere between 810 MB and 2.4 GB per hour, or between 13.5 MB and 40 MB per minute.
5) Corporate Propaganda — Prices are Going Down, Really?…
Corporate friendly AEI, claims that broadband prices have actually gone down according to two new reports.
“Broadband has been a bright spot in America’s grim inflationary landscape. While consumer prices rose 4.9 percent last year, the two recent reports show that consumer broadband prices fell, both in absolute terms and cost per gigabyte. But where many see a victory, some cities sense an opportunity. Stung by declining cable franchise fees, local governments are pushing to tax broadband. This effort faces severe regulatory headwinds, but if successful could erode consumer gains and drive broadband prices higher.”
We’ll address the attack on the municipal broadband movement in an upcoming story.
Gains? One new study by the USTelecom, the front group-association for the phone companies, talks about ‘inflation’ and the price per GB. As we discuss, these use meaningless benchmarks and standards to convince us they are right.
And, as we mentioned, Commissioner Brendan Carr’s 2024 Net Neutrality ‘dissenting view’ wrote:
“In real terms, the prices for Internet services have dropped by about 9% since the beginning of 2018, according to BLS CPI data. On the mobile broadband side alone, real prices have dropped by roughly 18% since 2017, according to BLS and industry data. And for the most popular broadband speed tiers, real prices are down 54%, and for the fastest broadband speed tiers, prices are down 55%, over the past 8 years, according to BLS and industry data.”
Real prices? That’s $.08 cents per gig in overseas countries with competition vs a sliding scale that ranges from about $3-$15 per gig in the US, though more research is needed as to the cost per GB and the total broadband bill.
We asked multiple AI programs a basic question: (November 15st, 2024)
- Does the BLS CPI data collect actual telephone bills via surveys?
- ANSWER: “No, the Bureau of Labor Statistics (BLS) does not collect actual telephone bills via surveys to calculate the Consumer Price Index (CPI)”:
- “Data collection The BLS collects price information for the CPI by visiting or calling thousands of businesses, service establishments, and rental units. Some prices are collected directly from websites or apps.”
In short, the FCC data has been and continues to be unreliable at best, and has nothing to do with the actual costs to offer the service or what customers are actually paying because it leaves out a library of charges, taxes on taxes, made up charges — and all of the customer bills where there are added services the customer did not order.
We’ve been critical about this failure to provide even basic information about communications rates since the 1990’s. NOTE: In 1994, New Networks Institute filed a complaint against the FCC’s data. New Networks Institute, at the behest of former Vice President Gore’s office met with the FCC.
- “THE FCC’S DATA ON PHONE COMPANY PHONE RATES, FINANCIALS, AND OTHER DATA ARE SERIOUALY FLAWED AND IN NEED OF MAJOR REVISION.” Original Filing: February, 3rd, 1994,Updated Complaint April 21, 1994.
NOTE: The IRREGULATORS (and previously Teletruth) also has a telecom auditing group, LTC Consulting, and combined we’ve taken 4 successfully settled class action suits pertaining to billing and overcharges, that were all presented first to the FCC, circa 2002. And LTC Consulting billing audits got small businesses, schools, government offices and municipalities refunds for overbilling for the last 2+ decades.
6) Junk Fees are added fees that are hidden from the total advertised price of service.
Over the last decade we have tracked the costs of communications services, and it is clear that America is being overcharged, big time, via the control of the prices and the regulators who can’t seem to remember they work for the public.
The Triple Play and “No Gimmicks” Overseas.
To demonstrate just how out of control America’s prices have become, the following are, 2 wired-based triple play bills, one from Free French Telecom the other from Charter Spectrum in Brooklyn, NY and both fall into the same range of other respected research about pricing including the EU Broadband Commission and Consumer Reports in America.
The price differential between these 2 offerings is enough to read the FCC the RIOT Act and have the Agency explain how the costs overseas can vary so greatly and why there are made up fees, taxes, surcharges, and costs for equipment that used to come with service and is now extra, as are a litany of other charges that should never have been allowed on America’s communications bills.
Here, the triple play — phone internet, broadband and cable service is 29.99 Euros and goes to 39.99 about $42–45.00. The US triple play in 2019, on average, was over $220.00 a month, according to Consumer Reports.
So, simply put, America is paying $175 a month extra (rounded). This French bill was for a 5Gbps speed over fiber to the home, and the programming even came with the succor programming — like the NFL football.
7) Verizon NY 2023 Annual Report Excerpt. Examining the cross-subsidies using the wireline state utility construction for wireless.
On May 23rd, 2024, the Verizon New York 2023 Annual Report was made public by the NY Department of Public Service.
We created a summary analysis of Verizon New York 2023 financial report and lay out billions of dollars in just New York State that should be used to upgrade the state with fiber optic wires to the home, even in rural and low income unserved and underserved areas, and immediately lower basic phone rates. This also addresses why America’s prices for all telecommunications, including wireless, broadband and internet should be immediately reduced — and what immediate investigations and actions should be taken throughout America.
Let us connect the dots.
- This analysis, combined with over a decade of research, state and federal filings, and basic financial accounting shows that Verizon NY’s financial books have been manipulated.
- The budgets for the fiber to the home had been diverted to wireless, starting around 2012, which was originally identified by the NY Attorney General’s Office in 2012.
- This meant that the entire upstate part of NY — and every Verizon state, was not going to have the copper wires replaced with fiber, but that budget would be used to build 3G, 4G and 5G
- There have been continuous rate increases on, not only the wireline access fees, but also on all of the voice, video and data services, thus inflating all of America’s prices and also customers were de facto investors. — i.e., got stuck illegally paying for the wireless build outs.
- Since Verizon controls the wires of the utility, then it also controls the wholesale prices of those reselling Verizon Wireless,
- Comcast, Charter-Spectrum and Cox all resell Verizon’s wireless service, so all of their prices are based on the Verizon starting point.
- Verizon, then, didn’t feel the need to do fiber to the home to compete with wireless or the cable co.
And here, in 2024, this annual report shows now only the flows of money for the state utility, but based on other filings, documents, etc. including filings by the NY Attorney General’s Office (in 2012) for wireless build outs, but within the financials are the fiber optic costs, which in turn, is used to set the wholesale prices for wireless.
8) The fiber optic wires are put in as part of the state utility as Title II, common carrier networks.
But it gets worse and crazier. The fiber optic wires are broadband and classified as Title II, and every pundit, politician, expert, analyst, advocate, and lawyer that failed to examine the basic facts have harmed America
This excerpt is from the New York State Public Service Commission and the Verizon New York FiOS offering — at the start.
- This means ‘broadband’ was always telecommunications, that
- Verizon et al., used this to charge customers for upgrades and for the wireless company.
- It also means that all data caps have to be examined based on this chain of revenues and expenses.
The wireless company services ‘aren’t regulated’, but these fiber optic wires are part of the utility and paid for via rate increases. More importantly, it was illegal to tie the ISP -which is NOT part of the utility but a separate online subsidiary and should have been making payments to the utility for the use of the networks. Verizon Wireless is NOT entitled to charge local intrastate regulated customers for wireless expenses.
9) Big Foot: The AT&T and Verizon “Footprints” Revealed
Virtually unknown by the public, much less the regulators, the current AT&T and Verizon are holding companies that now not only have the largest wireless subsidiaries, but are also in control of the wireline state telecommunications public utilities that were given to these holding companies for safe keeping as they have been and still are the states’ underlying critical infrastructure.
Thus, these 2 holding companies territories are the original Bell telecommunications public utilities — and these are actually the ‘footprints’ of the companies.
Why is this of critical importance? According to this footnote, AT&T only offered wired home Internet broadband service in their 21 state telecommunications public utilities — the AT&T ‘footprint’.
AT&T Footprint and the State Telecom Utilities are Tied to the Broadband Deployments.
The next map shows the fact-based reality that is missing from the conversation. All of these companies are based on a collection of state telecommunications public utilities which were part of the original Bell system,
And that means that they are already utilities, that each state had laws, regulations and obligations, which included fiber optic upgrades of the state wireline copper-based facilities and most importantly:
Verizon and AT&T have been illegally using these utilities as cash machines that have been illegally funding their wireless business and have illegally been using the state construction budgets, the rights of way and the primary fact — that for the last 3 decades the customers have been paying for these acts and paid for fiber optic upgrades they never got, and that they have been illegally paying for the other lines of business — cross-subsidizing wireless, for example, via the wireline, ‘intrastate” local phone service and wireline services, including data services.
The Footprints of AT&T, Verizon as well as Frontier and Lumen.
- AT&T Controls 21 States
- Verizon controls the East Coast from Massachusetts to Virginia, 8 state and DC utilities.
- Lumen, formerly CenturyLink, controls most of the other state utilities.
And just so we are clear on the original GTE and Verizon properties that were sold to Frontier and now Verizon wants to take them back: Verizon, which is the combination Bell Atlantic and GTE, decided to consolidate the East Coast holdings of Verizon and separated the GTE scattering of more rural than not locations, which are also state utilities, in multiple states.
Official Map of the Verizon and Frontier Territories, Previously Part of Verizon.
If you examine a state like California, GTE-Verizon was about 20% of the state whereas Pacific Bell, now AT&T California was 80% of the state.
10) We ask the Commission to investigate these issues now, as part of the data cap proceeding:
- The data caps on wireless are artificial as the starting point, the wholesale prices may be manipulated in multiple ways.
- The added junk fees may also be just the cost of business and should be removed.
- A complete analysis of the flows of money will reveal one of the largest accounting scandals in American history that makes America’s prices for communications obscene compared to the rest of the world.
- When the ‘chain of money’ and the revenues and profits are followed, we believe Verizon cross-subsidized their wireless business at the expense of getting the fundamental critical infrastructure built.
- Therefore, there shouldn’t be data caps in America unless the FCC and other government agencies can explain how overseas, some can get 100 GB for under $10.
