• On October 3rd, 2019, the IRREGULATORS discussed why this case, IRREGULATORS vs FCC, is critical for America’s communications future, from tackling Net Neutrality and the Digital Divide, to lowering prices and bringing in competition. We also discussed that 5G Wireless is a bait-and-switch; the service is not profitable and the telco plans will do America more harm than good.
  • NOTE: The IRREGULATOR response to the FCC is due October 10th, 2019.
  • IRREGULATORS v FCC Case Materials
  • Medium Article: Summary of the Case
  • Short Bios of the IRREGULATOR Team

We created audio podcasts, first supplying all of the main presentations, as well as a podcast for each speaker.

  • The Full Series of Presentations, 42 Minutes
  • Mark Cooper, Director of Research, Consumer Federation of America: An overview of the case.
  • Bruce Kushnick, Executive Director, New Networks Institute: The fiber optic history of broadband and internet in America and the mergers that created AT&T, Verizon and CenturyLink
  • Chuck Sherwood: The impacts on municipalities.
  • W. Scott McCollough, Esq, counsel: The reasons we took the case, the potential legal outcomes, the impacts on the states, as well as Net Neutrality and 5G Wireless.

TOPIC: IRREGULATORS v FCC is critical as it exposes a massive financial cross-subsidy scheme, costing America’s communications users an estimated $50–60 billion in overcharging annually. And, we uncovered it is based on the manipulation of the FCC’s cost accounting rules.

  • CASE STATUS: On April 15, 2019, the IRREGULATORS filed with the DC Court to appeal an FCC decision that continues the harms of the FCC accounting rules, while ignoring basic facts we presented over the last 5 years. On July 22nd, 2019, the IRREGULATORS filed our complaint (with our ‘standing’ unchallenged), and the FCC responded on Sept 12, 2019.
  • Again, the IRREGULATOR response to the FCC is due October 10th, 2019.
  • WHAT WE FOUND: State-based Overcharging: Over 5 years ago, the IRREGULATORS formed because we found evidence of massive financial cross-subsidies between Verizon New York, the state-based telecommunications utility, and all of the other Verizon lines of business, which includes Verizon wireless, online, Business Data Services and even FiOS, the fiber optic service.
  • SETTLEMENT: Using our research and the published Verizon NY Annual Reports, (hiding in plain sight), an investigation started and there was a settlement against Verizon NY in July 2018. Estimated at $300–500 million, it requires fiber optics to rural areas and fixing the deteriorating state-based, public-funded utility infrastructure.
  • FCC FEDERAL RULES ARE TO BLAME: However, we also uncovered that the FCC’s accounting rules, which are federal, are still in use and have been manipulated, impacting every AT&T, Verizon and Centurylink state utility, but also implicating every FCC decision, which are also based on using this corrupted accounting.
  • OUT OF CONTROL: This current FCC has been ‘weed-whacking’ the rules and has no plans to stop the billions per-state in cross-subsidies that have been allowed to go on. AT&T et al., with the FCC, have been able to hide and obfuscate this accounting scandal because it is too complicated and detailed for even the telecom experts and lawyers, much less the state commissions or the public.
  • Solving the Digital Divide, getting cities upgraded to fiber and bringing in competition to lower prices, requires exposing and removing the cross-subsidies to restart competition and give consumers choice. This new found fund, “liberated” from the accounting rules, both for compensation of past harms as well as proper future allocations, can be used to help pay for these activities.
  • The IRREGULATORS is an independent consortium of senior telecom experts, analysts, forensic auditors, and lawyers who are former senior staffers from the FCC, state advocate and Attorneys General Office experts and lawyers, as well as former telco consultants. Members of the group have been working together, in different configurations, since 1999.



New Networks Institute,Executive Director, & Founding Member, IRREGULATORS; Telecom analyst for 38 years, and I have been playing the piano for 63 years.

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bruce kushnick

bruce kushnick

New Networks Institute,Executive Director, & Founding Member, IRREGULATORS; Telecom analyst for 38 years, and I have been playing the piano for 63 years.