Not Secret, Just Sad

Comcast

Since I wrote about Comcast's failure to make their rates public, Comcast has notified me that their rate page for Montgomery County has been restored and updated to reflect current rates. Here is the URL:

http://mywebpages.comcast.net/comcast_mo_co/Index.html/Products-1.htm.

However, I still see that the Comcast rate page does not include rates offered by Comcast marketing partners such as comcastoffers.com and comcastspecial.com. In my last discussion with Comcast Customer Advocate Gloria Looper, she maintained that such offers are not subject to the disclosure requirements of MC. I think she's wrong and I will file an official complaint with the county's Cable Compliance Commission if Comcast fails to correct the omission in 30 days.

Verizon

Since Verizon is not presently a franchisee in MC, Verizon is not subject to the disclosure requirements. Hopefully that will change in the future.

But even from a marketing point of view, Verizon's website could do a much better job with providing rate information. The current website is confusion city - a disaster of poor user interface design combined with a push for products and bundles that don't make sense in our area.

As an example, when I go to www.verizon.com, roll my mouse over the word Residential, and suppress the immediate urge to click (even though it's a link) and instead wait for and click the Products and Services link that appears, I get a page with a bunch of banner ads, the largest of which is for DSL - which I already know I cannot get. In that page, I find a text link for FiOS. Clicking on that, I get prompted for my Verizon home number or asked to go to yet another page to enter my address. Since I don't have a Verizon phone, I select qualify by address, enter my address, get yet another page to confirm my address, and finally:

Our records indicate there is existing phone service at this location. Please enter the Verizon home phone number associated with this address so we can show you the specific high speed options available.

Yes, there is existing phone service (1st sentence is correct) but it ain't Verizon - so the request (2nd sentence) is impossible for me to fulfill. Indeed, I haven't had Verizon service at my address for three years! I've had VoIP for a year and a half; Before that, I was totally cellular.

So I have no number to enter and there's no alternative button or link to click. Entering my (non-Verizon) VoIP number anyway just takes me back to the earlier screen that prompts me to enter my address. Entering it, I see that I have indeed fallen into a loop. Sigh.

This is just the tip of the iceberg. When I click on the Bundles link from the Products and Services page, I get sent to another page that talks about DSL and traditional phone service, not FiOS and not their VoIP product (VoiceWing).

And remember how I resisted the urge to click on the Residential link earlier? Well, if you're not so fortunate (and I suspect most people won't be), you'll simply move your mouse to the word and click on it. This is the way web pages are supposed to work. You won't see the categories until it's too late - instead you'll have already ignored -- Your one-stop source for everything you need to stay connected at home. -- which previously occupied that space.

Then you'll be sent to a page that says nothing at all about FiOS and VoiceWing; Once more, it's all DSL and more useless packages. Oh, but there is a link for Product Recommender. However that turns out to ask totally confusing questions ("How do you prefer to make most of your phone calls? Landline, VoIP, or WireLess? Huh??) I particularly enjoyed the question asking which features are most important to me with one of the choices being realiability!

Is it possible that Verizon is losing potential customers because their web pages are so bad?

Secret Comcast Offers

A Little History

In 2002, Comcast merged with AT&T Broadband. In Montgomery County, this merger required that Comcast sign a document transferring control of the existing video franchise. One of the more interesting parts of the transfer agreement was the following:

4.8. The Franchisee will, at all times, post on its website all available rates for any cable or other service that the Franchise offers, including any promotional or special rates.

Not long after Comcast agreed to this provision, they delivered. A page appeared on the Comcast site listing every rate. It listed not just their promotions but also every nickle-and-dime charge such as the cost of sockets, extra boxes, remotes, and so on. This page has disappeared - or more specifically has become orphaned. Short of someone telling you its explicit URL, there's no way to find it. Effectively, it may as well not exist. Indeed, I spoke to several people at Comcast about the page this week. All of them denied its existence.

Back to the Present

If I surf over to comcast.com now, enter a Montgomery County zip code, and click on Products and Services, I get a page with 11 different products. But the number of products that Comcast offers is vastly greater than that. Their old web page showed over 75 different rates! For example, do you want:

• Digital Classic?
  
• Digital Plus?
  
• Digital Additional Outlet?
  
• Cable Latino?
  
• Premium? International Premium?
  
• Which of 6 different equipment rental rates?
  
• Extra IP addresses?
  
• Mini-Amp?
  
• and on and on...

Comcast also listed all their "Other Charges" such as:

• Unreturned Digital Converter: $225
  
• Unreturned HDTV Digital Converter: $325
  
• Unreturned CableCard: $115
  
• Late Payment Charge: $4

and of course...

• Returned Check Charge: $25

It really helped consumers to be able to see all these. I was able to pay $29.95/month for the last 12 months thanks to one Comcast promo that I wouldn't otherwise have known about.

None of these rates appear on Comcast's Products and Services page now. Nor do offers that I see on other sites appear here. (For example, Comcastoffers.com shows a 6 month deal for $19.99/month. Nor do I see offers that I've heard from Comcast representatives verbally (such as their $33/month deal - more on this later).

Given the 93% jump in my cable bill this month (from $29.95 to $57.95) and unable to find the current list of rates so that I could make an informed decision as to what to do about it, I decided to file a complaint with the county over Comcast's failure to to provide their rates as required.

A day or two after submitting my complaint, I was contacted by Gloria Looper of Comcast's Customer Advocate Group. Gloria said several things:

• Offers from outside companies: Comcast is not responsible for outside companies offering promos for Comcast service. She asserted that because it wasn't Comcast making the offer, it therefore didn't violate Comcast's agreement to publicize "rates that Comcast offers" even though the outside company was working with Comcast. I doubt this interpretation would hold up in court. Can Comcast really get out of promises by simply saying "We are not responsible for what our contractors are doing in our name?"
  
  
• Complete list of rates: Gloria (who has worked as a customer advocate for Comcast for a long time) had never heard of such a thing nor was she able to find such a page herself. While I waited on the phone, she contacted the marketing department - they weren't aware of it either. (When I filed my complaint with the Cable Office, the county investigator who took my complaint knew exactly what I was talking about. He too knew the URL where the page used to be.)
  
  
• Verbal offers from Comcast reps: Gloria at first adamantly denied the existence of such offers. Normally, it's pretty hard to support such claims but I felt I was on pretty solid ground with one example - Angela Lee (who heads the Government Affairs office at Comcast for our region) had described the $33 promo before the entire Advisory Committee just the day before. (The $33 offer: Subscribers that already have 1 or 2 Comcast services can add on all the remaining services at $33 per service to get Comcast's "triple play" of internet, video, and telephone.) Gloria had never heard of that either but after a another call to marketing, acknowledged its existence.
  
  
• Intentionally suppressed prices: The Comcast website describes Comcast's telephone service but insists that you have to call to get the price. What kind of marketing gimmickry is this? Will they set the price depending on the neighborhood you are calling from? Gloria explained that ... oh never mind, I won't even bother to repeat her explanation because it made no sense. I suggested she consider this another violation of the Comcast agreement. She said she would look into it further.

Bottom Line

If you know Comcast's rate structure, you can use that knowledge to save yourself a substantial amount of money. But don't depend on Comcast's representatives to help you out. Some Comcast representatives don't know about the deals, have an incorrect understanding of them (believing many promos are only for new customers is a popular misconception), or simply lack the inclination to work on your behalf and steer you to the lowest rates. So it's a good idea to check for yourself.

But right now you can't check. Hopefully the county cable office will get Comcast to live up to their obligation to list all their promos and rates. Until then, I advise you to be very cautious about signing up for new Comcast services or agreeing to higher rates simply because you got a bill or someone at Comcast told you to pay such an amount.

Rockville Resolution Residuum

On Monday, April 10, 2006, I attended a meeting of the Mayor and Council of the City of Rockville. On the agenda was the following:

Adoption of a resolution to encourage Verizon to install its Fiber to the Premises (FTTP) and make its FIOS service available to Rockville residents, and to comply with Rockville Permit and Rights-of-Way (ROW) Management requirements

The resolution was nominally a symbolic gesture that simply said Rockville wants Verizon to install its FIOS service already. Of course, politicians being what they are, the resolution took 3 pages and a half-hour presentation to state what I just said in the previous one sentence.

So what's the point of such a resolution? It's clear that it was not meant as a communique to Verizon. Rather, it was a self-defense against the citizens who have been pestering City Hall to no end. At least that's how I interpret this preface to the resolution:

Some citizen inquiries to the City have indicated that there is, among some citizens, a misunderstanding that the City is refusing to allow Verizon to install fiber optic cable and provide high-speed Internet service. The resolution seeks to clarify that the City is not refusing entry, and that the City encourages competition while appropriately managing the public ROW.

More Detail, More Money

To explain in more detail, Rockville wants Verizon to pay the following fees:

$4.35/ft for excavation of city streets
$2.20/ft for excavation of sidewalks and grassy areas
$0.06/ft for laying aerial lines

According to Rockville, Verizon has asked for an 85% discount on those fees.

Are these fees reasonable? Well, first let's examine what the fees are not for.

The fees are NOT for any direct damages caused by Verizon construction crews. If Verizon cuts a power cable, Rockville doesn't have to pay for it, Verizon does. The fees are NOT for repairs to the roadwork. If Verizon opens up a roadbed, Verizon has to restore it.

Fee This

So what are the fees for then? First of all, they're to cover the cost of infrastructure to collect the fees. If that was it, it would be ironic indeed - like tollbooths that continue to exist only to pay for their own upkeep. But that's not all. You also get a set of four ... oh wait, wrong commercial. The fees also pay for the upkeep of the rights-of-way (mowing the grass). That and plans, reviews of plans, plan permits, plan revisions, applications, application reviews, studies, variances, inspections, verifications, investigations for work without a permit. And meetings like the one I attended.

Undoubtedly there is some justifiable work in there but it sure makes you wonder how much is necessary. Wait, no need to wonder. The city hired consultants to count the beans. (Throw in a couple more beans for the cost of the consultants.)

The consultants report explained that the fees are set to recover all expenses involved related to the permits: city buildings, computers, support of the IT department, staff labor, pensions, ... everything. The premise underlying this computation is that... for any services benefiting or being provided to individuals, and not society as a whole, the individuals should pay for the cost of the service.

That premise in and of itself certainly makes sense. But how does it apply to the current situation? Is Verizon's fiber a benefit to the community as a whole? Or is it a benefit to specific individuals?

Verizon Fiber - Benefit To All Or Some

It could be argued that since only some individuals will ever make use of Verizon fiber, it benefits individuals and not the public as a whole.

On the other hand, it could be argued that Verizon brings competition and presumably, lower prices and incentives to provide improved service, even to non-Verizon customers. Is that a benefit to the community as a whole? Ok, not everyone is a high-speed internet customer but then not everyone is a library patron either and yet we agree that libraries are a benefit to the community. And while libraries are not-for-profit, high-speed internet service is recognized by the government as a resource that is not simply significant but increasingly necessary to the quality of life in the community.

I'll side with the benefit to the community camp. Indeed, I think it's a no-brainer. And the consultants report agrees! Wait, didn't I just say the report justified the rates? Well, yes and no. The report also said that its recommendations do not apply to utilities, specifically naming telecommunications providers as excluded from its recommendations! And the report goes on to point out that there are additional circumstances in which it might be regarded as a reasonable policy to set fees at a level that does not reflect the full cost of providing the service. In either case, one has to wonder - is the council misreading the report? Or is there something else going on here?

Neither of these points were mentioned during the meeting. Indeed, it was startling what else wasn't mentioned.

• No mention of what Comcast paid for ROW access in Rockville.
  
• No mention of what Comcast paid for ROW access elsewhere in MC.
  
• No mention of what Verizon paid for ROW access elsewhere in MC.
  
• No mention of what other communities charge for ROW access outside MC.
  

Instead, the testimony dwelled on a limited set of facts and another set of what I would call innuendo-laden asides such as this one: the City has diligently and in good faith pursued these negotations and, when there have been delays, has repeatedly invited Verizon to continued negotations. You gotta love that kind of rhetoric. The City isn't saying Verizon is slime; but only the City is diligent and acting in good faith.

The testimony also repeatedly noted (proof by repetition):

• The rates were fair based on other communities (without any evidence presented).
  
• No other company has requested a discount (without any evidence as to whether other companies were made to pay the current rates).
  
• A recent phone Verizon outage shows the burden Rockville must bear (without observing that Rockville was in part to blame).

In speaking to staff after the meeting, I was unable to get any further information concerning what Comcast may have paid either in Rockville or what either Comcast or Verizon paid elsewhere in Montgomery County. Subsequently, I contacted the Montgomery County Deptarment of Permitting Services and asked what Verizon was paying outside of Rockville. A representative could not give me specific figures but said that ROW permits were usually 'per job' and depended on things such as width and depth of cuts. However, he proceeded to offer top-of-the-head figures such as $97 for a minor road, $200 for a major road, or $1/ft for a grass shoulder.

The last figure is the only one directly comparable ($1/ft for MC, $2.20/ft for Rockville), however it should also be noted that Verizon in many cases doesn't even use the ROW in MC, either using easements (not subject to ROW agreements) or existing access for which they need pay no additional fee. (Some access requires an annual charge.)

While browsing the MC Permitting website later, I also noted the following: No fees are charged for most utility companies, but some utility companies & private companies doing work for utility companies are required to pay fees.

Bottom Line

Digging up figures from various jurisdictions and for various jobs was painful enough (and in part why this report was delayed as I waited and waited for responses that never came) that I'll dump it in Rockville's lap: I think Rockville has to explain the reason for the rates and why they are set so high as to be preventing competition in an area or, for that matter, why they are charged at all.

While it is true that Verizon's fiber upgrade in parts of the County has had significant problems and Rockville has a right to be concerned as they have ultimate responsibility, it also appears to be the case that Verizon is working out these problems, is acting in good faith, and has significantly improved to the point that Montgomery County wants Verizon to continue installing fiber to the remainder of the county as quickly as possible.

What I see here is not an economic cost-recovery issue but a political issue. Does Rockville want competition? Does Rockville have a vested interest in favoring a sole incumbent provider? I'd like to see the Rockville Mayor and Council cut out the hyperbole, drop the posturing, and think clearly and speak honestly regarding the future of competitive high-speed internet service in Rockville.

Meeting With Comcast

The next CCAC (aka TAC or Telecommunications Advisory Committee) meeting includes a Comcast representative (presumably the VP of Government Affairs). If you'd like a question posed, don't send it to me (which doesn't work now that the CCAC is refusing questions from the public during meetings). Instead, send questions directly to your CCAC representative.

You can check the Frapper map to find your nearest CCAC representative (look for the green icons). Most of them are publicly listed in the white pages. Call one up and express your thoughts. These people represent you!