I want to communicate with the FCC in regards to the proposed Charter-Time Warner merger. Unfortunately, I'm having much trouble navigating the FCC's web site. I found https://apps.fcc.gov/edocs_public/attachmatch/DA-15-733A1.pdf which is utterly incomprehensible. For example, the document says "We urge parties to use the Electronic Comment Filing System (“ECFS”) to file ex parte submissions." but it doesn't say where to find the Electronic Comment Filing System and it doesn't say what ex parte means. Furthermore, although the document lists your names and E-mail addresses, it goes on to say "(5) each Commissioner or Commission employee who attended or otherwise participated in the ex parte meeting." but it doesn't say who were the commissioners or commission employees who attended the meeting. Hopefully, you have the meeting minutes and can forward this message on to them.
If you take a look at the Federal Communications Act of 1934, the first section of the act says:
"For the purpose of regulating interstate and foreign commerce in communication by wire and radio so as to make available, so far as possible, to all the people of the United States a rapid, efficient, nationwide, and worldwide wire and radio communication service with adequate facilities at reasonable charges, for the purpose of the national defense, and for the purpose of securing a more effective execution of this policy by centralizing authority theretofore granted by law to several agencies and by granting additional authority with respect to interstate and foreign commerce in wire and radio communication, there is hereby created a commission to be known as the 'Federal Communications Commission', which shall be constituted as hereinafter provided, and which shall execute and enforce the provisions of this Act."[1]
Note that it says all of the people (emphasis mine). I suspect that the vast majority of American do not know what ex parte means. I happen to know what it means: 1) on or from one side or party only —used of legal proceedings 2) from a one-sided or partisan point of view, because I looked it up in a dictionary.
When I read documents like this, I realize that the government is in the thrall of entities (since the Citizens United decision, I'm not sure if corporations are people or if people are corporations, so I use the word entities) with sufficient money to hire lawyers to write this stuff.
I am not a lawyer. I'm a linux system administrator. I know full well about the technologies involved in running an internet service provider - the capital costs of stringing the wire, the cost of the infrastructure at each house or business, and the infrastructure at the data centers and points of presence where the providers cross connect. I know the cost of support people who actually know what they're talking about, compared with the cost of support people who ask you to reboot.
I also know, from economics class in high school, that better service and lower costs come from competition. Time Warner - Charter merger doesn't increase competition, it reduces it. No capitalist in his or her right mind would do something to increase competition. I am trying to visualize a CEO getting up at a shareholder meeting and say "We just increased competition by 50%, which means we're going to have to reduce our prices and our profits to compete". It boggles the mind.
Time Warner and Charter will argue that by merging, they get economies of scale. They will, a little. For example, right now, each company has its own, well paid CEO. Once they merge, they will need only one well paid CEO. I suspect that the CEO that's forced out won't be on the street corner, begging for change, but then, I've never asked somebody begging for change if they used to be a CEO. Right now, they have two marketing departments, two planning departments, two customer support centers. After the merger, they will need only one marketing department, one planning department, and one customer support center. Of course, they will have more customers, so the customer support people will either be more overworked than they are now, or else the company will have to hire more customer support people, so I don't think there is going to be much saving there. Furthermore, they still have to wire up every house in America. Because of less competition, the company will be less likely to gain a marginal competitive advantage by wiring up poor neighborhoods. So they're really not going to save as much money as they claim they are going to.
Finally, there is a question in my mind if the merger is even going to "work". I read an article in the Harvard Business Review, which I would consider to be an authoritative source, that 90% of all mergers fail. What I foresee happening is that the companies will take on a lot of corporate debt in order to accomplish the merger, they will pay a small fortune (or maybe a large fortune - I don't know how to quantify "fortune") for lawyers and accountants and consultants to make the deal happen. That money could have gone into investment in infrastructure, salaries for employees, or dividends for shareholders. The corporate debt will have to paid, and the cost of the debt service will be a drag on profits.
In other words, my ex parte submission is that Charter and Time Warner are run by a bunch of greedy idiots.
I want you to reject the merger in the interests of their customers and their competitors.
If you have any questions or responses to my comments, please feel free to contact me at the addresses below. Thank you for your consideration.
Sincerely yours,
Jeff Silverman
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Jeff Silverman, linux sysadmin
nine two four twentieth avenue east
Seattle, WA, nine eight one one two -3507
(253) 459-2318
jeffsilverm@gmail.c0m (note the zero!)
http://www.commercialventvac.com
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