According to Comcast, there are 11 video providers in the New York metropolitan area, and an amazing 29 broadband providers. Sounds like competition, right?

This is epic bulls**t, and I do not use that word lightly.

Comcast didn't make its full lists of supposed competitors public, but I can dismantle them pretty easily. My list is specific to New York City, although I'm pretty sure you'll find at least some of these fallacies in other large metro areas.

All this just goes to say that the Comcast/Time Warner merger shouldn't be treated as a merger of struggling, competitive broadband providers. It should be treated as a merger of dominant, monopoly broadband providers – with the concomitant regulation.

Let's start by noting that in my part of New York City, Time Warner Cable offers 15Mbps Internet for $34.99 per month to every local resident, with no data cap. If the market was "competitive," similar offerings should exist. Here's what's on Comcast's "competitor" list.

Other Monopoly Cable MSOs

Cablevision appears on Comcast's competitor list, which is ridiculous because like Comcast, Cablevision is an exclusive franchised MSO – it has no overlap with Comcast and TWC service areas. If Comcast and TWC don't compete, then Cablevision competes with neither of them.

Competitive Cable and Fiber Services

RCN, Verizon FiOS, and AT&T U-Verse pop up as video and broadband competitors, which would be nice if they actually offered service across the metro area. But FIOS and RCN coverage looks like a patchy rash, and both companies require a minimum commitment before entering any multi-family building, so even within their coverage areas, many residents don't have them as options.

Google Fiber would make an interesting competitor if it was coming anywhere near the nation's most populated metro area. But it isn't.

Wireless Broadband

AT&T says that the average home broadband user consumes 21GB of data per month. T-Mobile plans only go up to 11GB. Sprint tops out at 12GB. A 20GB plan on AT&T or Verizon Wireless costs around $130/month, which isn't a competitive price against cable.

Satellite TV and Broadband

DirecTV and Dish do make viable TV service competitors across much of the country, but not in cities like New York where landlords frequently forbid the installation of satellite dishes on the outsides of buildings. Satellite broadband, meanwhile, is extremely expensive per gigabyte. Satellite provider Wildblue's only plan that exceeds the 21GB home average, a 25GB plan at 12Mbps, costs $129.99 per month.

DSL

And finally we get to the one sorta-viable broadband competitor, DSL. Within New York City, Verizon offers DSL up to 15Mbps, with 768Kbps upload. Time Warner Cable offers up to 100Mbps with 5Mbps upload, so no, DSL isn't doing a very good job competing.

Furthermore, not every location in New York City is eligible for a 15Mbps DSL connection. Take my building, in the crowded and central neighborhood of Jackson Heights. Checking on the Verizon website, I'm only eligible for a 3Mbps connection because of my distance from the DSL central office. For fast Internet, Time Warner Cable is actually my only choice.

More Fabulous Quotes from Comcast

Comcast's FCC filing has an amazing amount of chutzpah. With so many half-truths in the 680-page document, I'll just stick to five.

1. "Approximately 70 percent [of Americans] are located in census tracts where two or more providers reported offering at least 10 Mbps downstream and at least 1.5 Mbps upstream."

As I discuss above, "in the same census tract" doesn't mean "available." A few buildings in my neighborhood have RCN while the vast majority don't, for instance. Yet that means RCN is available in my census tract.

2. "Numerous DSL providers offer speeds equal to or exceeding the Commission's broadband speed threshold at affordable prices. For example, Verizon offers DSL service at speeds up to 15 Mbps, Frontier offers speeds up to 25 Mbps, and CenturyLink offers speeds up to 40 Mbps."

As I discuss above, "up to 15" can often mean "3," which is a number below 15.

3. "Verizon appears just as eager to compete with its DSL and FiOS FTTP service."

Verizon has confirmed it will not expand FiOS to any new markets.

4. "Google, for example, is now deploying a competitive fiber network in several areas of the country."

A tiny amount of coverage, and irrelevant in major markets like New York and Los Angeles.

5. "For a large number of Americans, wireless is already a meaningful broadband alternative."

Only if you don't intend to use a PC, Smart TV, set-top streaming box, or anything other than a phone or tablet, as wireless plans for non-phone/tablet devices have restrictive data caps.

And it goes on. I still think this merger is unstoppable. But as I've said before, the government should extract several pounds of flesh in the process – hopefully, demanding that cable companies become common carriers and support competing services as virtual broadband operators at wholesale rates. That's the only way we'll get true home broadband competition in this country.

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