Verizon Files Suit Against Montgomery County

Today , Verizon sued Montgomery County, Maryland. I've never reprinted a press release before but this one speaks for itself:

June 29, 2006

Media contact:
Harry Mitchell, 304-344-7562

WASHINGTON - In an effort to bring video choice and competition to citizens of Montgomery County, Maryland, Verizon today filed a federal lawsuit against the county for its unreasonable and illegal cable-franchising process and demands.

The suit, filed in U.S. District Court for the District of Maryland in Greenbelt, asks the court to declare that Montgomery County's cable franchise process and requirements violate federal communications and antitrust law, as well as the First Amendment to the U.S. Constitution.

Verizon is asking the court for a preliminary injunction invalidating Montgomery County's current cable franchising law and directing the county to negotiate a franchise with Verizon on lawful terms within 60 days. At the same time - in an effort to help speed the negotiations to resolution - Verizon is asking the court to invalidate the numerous unlawful requirements the county is attempting to impose on the company.

"Verizon regrets having to take this step, but the county's unlawful demands leave us no other choice," said John P. Frantz, Verizon vice president and associate general counsel, who is leading the company's legal team on the case. "We would prefer to reach agreement on a franchise that would offer Montgomery County consumers more choice for their cable services, but after a year of essentially fruitless negotiations, we are at an impasse."

Montgomery County's Demands Hurt Consumers, Protect Incumbent

Over the year that Verizon has been negotiating to obtain a franchise to offer its FiOS TV in Montgomery County, county officials have made numerous unlawful demands that have stymied the negotiations. For example:

• The county asserts the right to collect fees on, and otherwise regulate, Verizon's telephone and broadband Internet service, in clear violation of federal law. In addition, the county claims authority to regulate the engineering, construction, placement and maintenance of Verizon's entire fiber-optic network once the company starts offering video service, again in clear violation of federal law.
• The county is demanding that Verizon set aside roughly 65 channels of digital capacity for public, educational and governmental programming, even though the county currently has programming for only 11 channels. Verizon wants to use the channels the county is insisting the company set aside to deliver programming that county residents want to see.
• The county is demanding that Verizon pay hundreds of thousands of dollars to cover the fees that the county owes to its own private consultants and attorneys; federal law forbids such demands.
• The county is demanding additional cash and free services as a condition for granting a franchise; it has no right to demand such terms under established federal law.

"We're frustrated at the lack of progress in these negotiations, because the inordinate delay benefits only the monopoly cable incumbent," said Frantz. "Meanwhile, Montgomery County residents continue to suffer, held hostage to Comcast's ever-rising cable rates."

Comcast has increased Montgomery County cable rates more than three times the inflation rate since 2000. In Montgomery County, the stalled franchise negotiations are costing county households more than $725,000 a month in possible savings.

"Competition will bring lower prices, more innovation and better quality," said Frantz. "It's past time for Montgomery County residents to join their neighbors in Howard County and Northern Virginia who are reaping the benefits of cable competition and choice."

Montgomery County is the only place in the Washington metropolitan area where Verizon has sought a franchise and has not been able to obtain one. In Maryland, Howard County, Bowie and Laurel have all granted Verizon a franchise; Anne Arundel County is poised to do so July 5; and Verizon's negotiations with Prince George's County are on track for an agreement by late summer. In northern Virginia, Verizon has obtained franchises from Arlington, Fairfax, Loudoun and Prince William counties; the City of Fairfax, Dumfries, Herndon, Falls Church and Leesburg; and the Marine Corps Base at Quantico.

Montgomery County Neighbors Enjoy Cable Choice, Competition

In other markets where Verizon has introduced FiOS TV - including neighboring Howard County - cable incumbents have responded with lower prices, more innovative bundled offerings of phone, broadband and video service, and increased broadband speeds.

Verizon's standard FiOS TV package, FiOS TV Premier, offers 180 digital video and music channels, two dozen high-definition channels and access to an extensive on-demand library for $39.95 a month. Comcast's most comparable cable package costs $68.60 in Montgomery County.

A family that switched to Verizon's video offering would save more than $300 a year and get more for its money. Verizon currently offers numerous other channels not provided by Comcast, including the Mid-Atlantic Sports Network, which broadcasts Washington Nationals baseball games.

The competitive response to Verizon's entry to the video market is swift and dramatic. In communities where Verizon already is offering FiOS TV, incumbents initially responded by slashing prices by 28-42 percent.

"Verizon's interest in this is simple," said Frantz. "We want the ability to bring choice and competition to Montgomery County consumers as quickly as possible, and we want Montgomery County officials to do the right thing by their constituents to make that happen."

More Detail

A summary document provides more detail about the basis for Verizon's lawsuit. Some of it sounds accurate and some of it doesn't but without the filings (not yet available), I can only speculate (and will do so as I find out more info). In the meantime, here is the summary document:

SUMMARY OF VERIZON’S COMPLAINT AGAINST MONTGOMERY COUNTY, MARYLAND
In May 2005, Verizon asked Montgomery County to grant a franchise to offer cable service in competition with Comcast. A full year later, the county has failed to approve Verizon’s application. Instead, county officials have responded by demanding that Verizon agree to a host of unlawful requirements as a condition for getting a franchise.

MONTGOMERY COUNTY’S ILLEGAL ACTIONS

Montgomery County’s Cable Franchising Process Violates the First Amendment.

• By adding cable television to its menu of communications services, Verizon seeks to engage in a form of speech protected by the First Amendment. Local laws licensing speakers must spell out narrow, objective standards that limit the discretion of government officials in deciding whether to grant franchises and what conditions may be attached.
• Montgomery’s County’s cable franchise process violates the First Amendment because it delegates to county officials discretion to approve or withhold franchises at will, to charge any fees they wish, to condition franchises on any demands they see fit, and to render decisions on any timeline they choose.
• The First Amendment requires that local authorities issue franchises in a timely manner. Yet county officials told Verizon it would take until at least November 2006 to grant a franchise, even if Verizon agreed to all the county’s illegal demands – a full 18 months after Verizon first asked for a franchise.

Montgomery County’s Franchise Demands Violate the Federal Communications Act.

• The Communications Act expressly prohibits local governments from exploiting their control over cable franchises to seize control over telephone and broadband Internet services. Yet county officials have, by ordinance and regulation, imposed a host of requirements on broadband and telephone services, as well as a series of rules governing the construction, operation and maintenance of Verizon’s telephone network, to which Verizon would be subject once it begins offering video service.
• The county has no justification for these requirements. Verizon is selling broadband and telephone services in Montgomery County today free from these regulations. There is nothing about Verizon’s offering video programming that suddenly creates a need to regulate its other services.
• Federal law limits the fees the county can collect to 5 percent of Verizon’s cable revenues. Montgomery County’s cable ordinance requires Verizon to pay 5 percent of its revenues on all services, including Internet service.
• In addition, to secure a franchise, the county has demanded that Verizon pay an additional 3 percent of its revenues to cover the county’s cable programs; provide free cable service to hundreds of government and private buildings around the county; pay hundreds of thousands of dollars to cover the county’s consultants’ and attorneys’ fees; and provide additional cash or free services on top of all these other concessions. Federal law prohibits all of these demands.
• The county’s contention that its actions are justified because it imposed the same requirements on Comcast is specious. Comcast’s franchise provides that if the county negotiates an agreement with a new entrant that requires smaller monetary contributions, Comcast can renegotiate its agreement to match those terms. This is not a question of competitive equity, but of county officials being unwilling to part with the perquisites offered by a cable monopolist.
• The county does not need the money. It is projecting a surplus of roughly $1 million for its cable fund in fiscal year 2007.

Montgomery County Is Enforcing Its Franchise Agreement With Comcast in a Way That Violates Federal Antitrust Law.

• Congress outlawed exclusive franchises in 1992. Prior to that, cable operators often offered perks over and above what the law required in order to win monopoly control of a market. The cable operator could then exploit its monopoly position to recoup the costs of these give-aways. Incumbent cable operators continue to employ this strategy to raise barriers to entry.
• The county has interpreted Comcast’s franchise agreement to block the county from offering a franchise agreement to a Verizon on different terms. This halts competition and protects Comcast’s monopoly. By entering into an agreement with Comcast that ensures the county will impose cost-prohibitive terms on new entrants, effectively blocking entry, the county has violated federal antitrust laws.

COMPETITION WILL BENEFIT MONTGOMERY COUNTY CONSUMERS

If allowed to compete in Montgomery County, Verizon’s FiOS TV will introduce much-needed competition and create significant benefits for cable customers.

The Lack of Cable Competition Is Harming Montgomery County Consumers.

• Control of the Market … Comcast currently controls the video market in Montgomery County. Roughly two-thirds of all households in the county, and roughly 75 percent of households that purchase cable or satellite service, subscribe to Comcast.
• Rising Prices … Because of a lack of competition, Comcast has been able to raise prices in Montgomery County by 25 percent since 2000 – nearly three times the rate of inflation. From 2004-2005, Comcast raised prices by 6 percent.
• No Competition … While satellite service is available, the FCC has determined that satellite is not effective at constraining price increases by cable companies.

Competition Can Constrain Comcast’s Price Increases.

• Competition Works … In its March 2006 report on video competition, the FCC found that in areas with real cable competition, monthly cable rates are 16 percent lower and customers pay 27 percent less per programming channel.
• Delay Costs Consumers … Nationwide, the delay in wireline competition is creating economic losses of between $8.2 billion and $21.4 billion per year.
• Montgomery County Consumers Are Paying a Huge Price … Thomas Hazlett, an economist at George Mason University who submitted a declaration in support of Verizon’s case, concluded that the county’s actions are costing residents more than $725,000 per month.

Verizon’s FiOS TV: A Much-Needed Competitor in Montgomery County.

Customers who switch to Verizon will save money. Verizon’s standard digital package costs $28.65 less than the comparable package offered by Comcast in Montgomery County. A family in Montgomery County that switches to Verizon could save more than $300 per year.

Even customers who don’t subscribe to FiOS TV will benefit from competition. In communities where Verizon has been allowed to compete, cable prices have dropped 28 to 42 percent.

• In Keller, Texas, the first location where FiOS TV began competing, Charter lowered its rate by $16 per month or 28 percent.
• In Herndon, Va., Cox dropped its price from $52.44 per month to $30 per month after FiOS TV entered the market.
• In Temple Terrace, Fla., Bright House lowered its price from $58.45 per month to $36.33 per month.

Verizon carries the Mid-Atlantic Sports Network, which broadcasts Washington Nationals baseball games. This is just one of the many channels Verizon carries that Comcast does not.

Anyone from the Montgomery County Executive's Office or Cable Office care to respond?

No Shows All Around

This week's Telecomm Advisory Committee meeting was lightly attended. The Verizon representative rumored to be there wasn't. A rep from RCN (aka StarPower) was officially given time on the agenda - and didn't show. And the two humiliated Comcast reps from last month didn't return.

And they might have been justified. Indeed, Jane Lawton was absent as well. As I understand it, she's officially back as the MC Cable Administrator but also still serving as a state delegate. The term was supposed to be over last month but the Governor wanted the entire Maryland General Assembly to stick around for awhile and try to address soaring energy rates. And her office reports that Jane will be running for her delegate position again. Since fall elections aren't that far away, it's only fair to wonder how much time she'll have to commit to cable issues during the campaign season.

One thing on Jane's mind is that her future may be more secure in Annapolis than in Montgomery County. Bills currently pending in Congress appear likely to strip away local cable regulation and pass it over to the FCC. Is that good? Well, it's good if you're concerned about obscene language. Regulating four-letter words on broadcast TV - the FCC has been good. But reining in soaring cable costs - not so good. And unless you can get a hundred thousand of your close friends to write to the FCC that your bill is wrong or your cable drop wasn't buried deep enough and was just cut by the landscapers, well, forget it.

The leading bill in Congress would nationalize the franchise system. The obvious benefit: Competition. According to Consumers Union, Americans who have a choice between two cable companies pay about 17% less on average. And cost is only one aspect that would likely improve. Being able to choose another provider (even if only one other choice) gives you a lot of power. All of a sudden, you're in control over who gets your hard-earned coin.

Is competition a total win? No. Although service may improve from competition, another concern is that the new bill contains no language forcing companies to provide service to everyone. If you live in a demographically-incorrect area, you may be out of luck. Well, you can move. Or band together with neighbors for community WiFi or community fiber. Hey, the local government may find a new role supporting these efforts! (Indeed, amendments to the bill support this idea.)

Sadly, the propaganda from both sides distorts the true advantages and disadvantages. For example, even traditional franchises have never provided guarantees of so-called universal coverage (a concept in and of itself of questionable merit). I take issue with claims of the Cable Office and its lobbying organization(s) as much as I take issue with the claims of the cables and the telecomms.

There are many other issues affected by these proposed bills (net neutrality being another world of distortion propaganda). I'm not going to get into them except to mention that the details in the bills are far from settled. It's been reported that there were over 200 amendments tacked on to the leading bill and god only knows what will happen once the bill goes into conference where legislators will add language never before seen by the public. From articles I've read in the Post, interested companies have sent hundreds of lobbyists to Capitol Hill and are spending millions of dollars per day pushing their interests on members of Congress.

Think Local

So what does this all mean locally? Well, the latest word from the Cable Office is that, once again, there has been no progress on a video franchise for Verizon in Montgomery County Maryland. Although no one is talking freely, it is apparent that nothing will happen locally until the bills in Congress either pass or die. And it seems pretty clear that the fighting will rage on for months. Bottom line: Unless MC and Verizon start talking, it will be at least a year before we see FIOS TV, even under a national franchise.

Curiously, the Cable Office had a meeting the following day (Thursday, June 22 '06) to which it invited the municipalities that MC normally represents in franchise negotations. According to the Cable Office, the meeting was to inform the municipalities of the status of the Verizon franchise. But why now - when there's been zero change in the status for months? Is it possible that some of the unhappy munis are negotiating with Verizon on the side, desparate to get around the county deadlock? If so, the county would surely like to squelch that before a domino effect completely undermines the county's position. Can any municipal representatives reading this offer their insights?

Vital This

As if to remind us that they are still a vital piece of the system, the Cable Office noted that:

• Comcast complaints were up last month, primarily regarding exposed drops.
• Comcast was out of compliance with respect to several different customer service measures and has thus been sent a warning as a prelude to a fine if they don't come back into compliance within the next quarter.
• RCN was late with franchise fees so they will now owe late fees. As I recall, the same thing happened last year. Is it serious cash-flow problems at RCN or just utter incompetence in their finance department? Too bad - because the county received only 3 billing complaints from RCN subscribers for the entire month of May. That's it. No customer service complaints, no installation complaints, no marketing complaints. That's a good record.

I shouldn't be too hard on the Cable Office. I appreciate the fine work they do - and yet I'm also frustrated at the limited reach they have given the fees they collect. (Did I mention that language in the national bill will ensure that locals continue to get their 5% franchise fee?) For example, the Cable Office is great at investigating safety issues such as ungrounded drops but the Cable Office can't touch frustrations like the incompetence of the phone reps at Comcast and the inability to be able to speak to a knowledgeable supervisor. (At last month's meeting, one TAC member speculated that Comcast doesn't actually have supervisors. It's just an empty title so that the front-line reps can say that "There are no supervisors around now, but I'll have one call you back." Has anyone been called back by a supervisor? Ever?)

And there's nothing that local regulators can do about prices in the upper tiers and the creative games that Comcast plays in making packages that include channels that no one wants. As an example of this nonsense, last month Comcast introduced a new package: The Family Tier, nominally for child-safe TV watching. Let's be honest - the only child-safe TV watching is no TV watching. The true reason for Comcast's new package was to head off Congressional interest in forcing a la carte subscriptions. A la carte would allow people to subscribe to just the channels they want. But this is the last thing that video providers want to provide. They figure that by offering a few more packages, they can claim that they are providing people with choice. And so far, Congress appears to have gone along with this charade. Have any customers swallowed this nonsense and signed up for this tier?

Triple Play Attraction/Repulsion

At dslreports.com, Karl Bode wrote about the Triple Play concept that I analyzed recently. As I said at the time, it's got some benefits but a whole lotta negatives. For example, in Comcast's case, the big negative is price. You ought to be getting a deal; in reality, the 'deal' is awful. And Karl notes that few customers are signing up for triple plays (and in some cases, quadruple plays). Here's Karl's take:

Karl Bode On The Triple Play

If you listened solely to ISP press releases, you'd think that the triple-play bundle is all the rage, and that the majority of customers are lining up to pay one company $100+ for three or more services. In reality, most customers still prefer to grab one or two services, and frequently can net better bargains by shopping around for their third or fourth service - be that video, wireless, or VoIP.

According to a Jupiter Research survey from March, only five percent of subscribers sign up for the triple-play, and only around a quarter of all customers are interested in nabbing all services from a single provider. "The assumption that everybody wants a bundle is flawed," a Jupiter analyst told the Washington Post last March.

This week a new study by Pyramid Research claims most customers are interested in either one or two services. The study finds that "most telcos are selling 1 to 1.5 revenue generating units (RGUs, aka one service) per customer while cable companies perform slightly better, selling around 1.5 to 1.9 RGUs per customer" (thanks to cable deploying VoIP faster than telcos are deploying video).

The report almost laughs at the idea of the "quadruple play."

Occasionally you'll catch rare candid admissions by incumbents that customers aren't quite as keen on the triple-play as their press releases would lead you to believe. For example, Time Warner's CFO recently admitted that only 7% of his company's customers subscribe to three services, and the majority only purchased a single service.

Whenever this topic is breached, there's a chicken and the egg debate here that springs up: are customers really saving significant money by bundling? Or are they being penalized for not bundling in environments where competitive choices are lacking? Comcast's stand-alone broadband service remains ridiculously expensive for someone who doesn't watch television. Similarly, stand-alone VOIP from Comcast costs a whopping $55.

Bundling is, in part, an effort by providers to obfuscate the real price of services, clouding the consumer's ability to directly compare single-service prices. Once a customer has switched to a single-provider, they're frequently greeted by unexpected fees, and the cost-savings they expected are nowhere to be found.

Upcoming Advisory Committee Meeting

The next CCAC (aka TAC or Telecommunications Advisory Committee) meeting is scheduled for June 21 at 7pm. The meeting will be held in Room 225 at 100 Maryland Ave., Rockville, and is rumored to include a Verizon representative. It would be nice if she were to address the status of the FIOS TV franchise but I don't expect it - all the negotations are being kept private - although snatches have escaped on occasion. At the same time, franchises are being hotly debated in Congress so a local franchise may be a moot point. Verizon may well have written off the MC franchise given its success to date lobbying Congress for national franchise legislation (it's already passed in the House).

If you'd like a question posed, send it directly to your CCAC representatives. 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!

The Best Deal For Comcast Customers

Computers are too damn complex. When my email stops working, I know how difficult it can be to narrow down the problem. Is it my broadband provider? My mail provider? My computer? My router? My toaster oven?

I have a more complex setup than most people - I use a 3rd party email provider. I accept the additional complexity of this but many people would not - they want the same provider for both email and broadband. They figure that broadband providers provide basic email service for free anyway. Plus, there's less fingerpointing when things break.

Wouldn't it be even better if we could simplify even further? Hey, broadband providers can! Internet service, video service, and phone service all from one company. One bill. One number to call for problems. Lately, I've been seeing the One Bill mantra played up more and more in advertisements. Not so much for the One Number For Problems though - I guess no one wants to focus on problems (especially when there are so many of them).

A Good Time Was Had By Almost All

I was reminded of the goal of simplification during the most recent meeting of the Montgomery County TAC (Telecommunications Advisory Committee) on May 18 2006. A good time was had by all. Well, all except the two Comcast representatives who gave a briefing to the committee. Admitting that things had not been going well in Montgomery County for some time, Angela Lee and Erin Pinkney attempted to put the right spin on it.

Angela, Comcast Senior Director of Government Affairs for MC and PG (and soon to include Frederick, thanks to the purchase of the Adelphia market but pending a lawsuit) described how complaints were now at a "very low level, lower probably than in years." Oooh, don't you just love unprovably vague assertions?!

Let's recast that in a different (but equally vague) way: Comcast's complaint levels have been so bad for so long, that anything has to be better. (See how this game is played?)

Attempting to shift the blame as much as possible, Angela noted that the number of problems (without giving an actual number, of course) due to Verizon construction was down significantly. (So Comcast replacing their area General Manager was just an everyday personnel change?)

Remind Me Why I'm Here

Erin Pinkney, Area Director of Marketing for Comcast, then had her turn. Apparently under a total misimpression as to her purpose for being at the meeting, she launched into a description of Comcast's latest products. Actually, a better phrase would be Comcast's latest marketing because that's all it was. Same products, different promos.

The committee politely listened to Erin go on about how customers want simplification (which she termed "lifestyle simplification" ) for about 15 minutes. Finally one committee member rudely interrupted and said: So my cable was cut for 3 weeks - no service - and only after I filed an official complaint with the county did I get a temporary drop. You promised me it would be replaced in 30 days but it's been 5 weeks - when are you going to fix it already?

At this point, the concept of simplification fell on the floor as committee members let loose with a barrage of questions and comments - paraphrased below. After each, I've shown Comcast's paraphrased response:

TAC: You're offering phone service? What are your reliability figures?
TAC: How can we be assured that your E911 is reliable?
TAC: I wouldn't trust my phone service to Comcast.
Erin: We have a new culture at Comcast!

TAC: How will you deal with phone outages? These are important!
TAC: How can I report outages if my Comcast phone is out?
Erin: Ask our Director of Technical Operations!

TAC: Why doesn't Comcast send out people who can fix the problem? I'm tired of getting people visit me who say "Oh, you need a line tech."
Erin: Miss Utility is causing severe delays!

TAC: Why can't we get Nats games?
Erin: We're negotiating!

TAC: Why is Comcast failing to provide us with FCC-required close-captioning statistics.
Erin: Write us a letter.
TAC: We did already!
Erin:

TAC: We're still seeing Verizon-related construction problems.
Angela: Yes, but less so.

TAC: Channels are disappearing from the analog band, will we get price reductions?
Erin: No, but we'll give you a free month of digital!

TAC: Why are additional digital boxes so expensive?
Erin: ... completely non-responsive ...

As you can tell from the last answer, I got tired of writing down questions followed by non-responsive answers. Indeed, the only reason I wrote down as many as I did is because they were, quite simply, outrageously entertaining in their non-responsiveness. Ok, the answer to the Nats question was responsive ... albeit useless.

To elaborate on a few:

Erin used the phrase new culture at Comcast several times in her answers. This came up yet again after one extended diatribe by a committee member who works for Geeks On Call. He frequently has to call Comcast on a customer's behalf - so he's got plenty of experience. He described typical interactions like this:

Comcast: Do you have your own router?
Customer: Yes.
Comcast: Then the problem must be in your router!

After describing how unhelpful the Comcast phone reps were, the same committee member asked directly: So what do you mean by "new culture at Comcast"?
Erin: I mean a new culture from a marketing perspective!

That certainly left everyone speechless! And in response to another question, Angela expanded: There is a focus on customer service! and she requested to Bear with us! Hmm, I've never seen that latter phrase in Comcast's advertisements!

Promos That Backfire

Speaking of ads, Angela and Erin went over a new promotion: the Comcast Triple Play. It works like this: If you don't already subscribe to all three of video, internet, and phone, you can do so at $33/month for each additional service for 12 months.

Who might find this attractive? I see the pricing targeted at 3 different groups:

1. Comcast TV and HSI (internet) customers who don't like the high price Comcast is asking for phone service.
   
2. Comcast TV customers who don't have Comcast HSI but are looking at (or already have) Verizon FIOS and traditional phone service.
   
3. Comcast HSI customers who already have satellite TV and traditional phone service.

In each case, there are substantial discounts to be had. For example in case 1, Comcast's deal is a 17% discount off their nominal cost of phone service. In case 2, Comcast is undercutting their own internet price by 23% as well as Verizon FIOS by 8%.

There are some differences in the internet service between Comcast and Verizon and I'm not going to go any further into that. And I'm not going to try to compare Comcast TV with the satellite equivalents - because they're harder to compare.

But it is easy to find a better price for phone service than Comcast's deal (which quite frankly is absurdly overpriced). Indeed, Verizon's VoiceWing (unlimited nationwide) package is $24.95. And there are even cheaper deals out there.

But if you want lifestyle simplification (to use Erin's phrase), Verizon should be considered. For example, say you're the typical long-term Comcast customer considering Comcast's offer for their Triple Play. So you have Comcast HSI+TV and are paying $96.60 (before taxes and fees). Add on Comcast phone for the special $33 and you're up to $129.60. But if you wanted to get the same three comparable services from Verizon, it would be Verizon-DirecTV ($44.99) + VoiceWing ($24.95) + FIOS ($34.95) for a total of $104.95. That's significantly lower. And the disparity is even greater if you're a Comcast Digital TV customer.

So if you're a new customer, the Comcast deal looks good - $99 for all three services. That's $5.95 less than Verizon. But Comcast's deal doesn't look too good if you're an existing Comcast customer. For substantial savings, you're far better off switching to Verizon. (Plus you get significantly higher upload speeds.)

Ironic, isn't it? If this new Comcast promo makes anything clear, it is that the best deal for Comcast customers is to leave Comcast.