Universal Subscribership

Universal Subscribership continued

The Commission generally has adopted a deregulation approach, allowing cable VOIP providers of telephone service to operate without regulation of prices, terms and conditions of service. This may have allowed practices which contribute to the low household subscribership in New York. This changed somewhat in 2012, when Time Warner, seeking to obtain subsidies for low income Lifeline service, sought recognition of its status as an “Eligible Telecommunications Carrier” (ETC), which was granted.

This change in status means that Time Warner’s service to its home telephone customers became fully subject to New York state regulation, including the Telephone Fair Practices Act (TFPA), and Time Warner’s low income customers became eligible for Lifeline rate assistance.

In contrast, Comcast has not requested ETC status regarding telephone service to its New York customers. As a consequence, they are not eligible for Lifeline assistance, their service may be shut off for nonpayment of TV bills, they may not be able to enter into deferred payment plans to avoid termination when they fall behind, shutoffs may occur on weekends or at night, and they may not have recourse to the Commission’s Hotline and complaint remedies. The Commission should require that Comcast seek ETC status like Time Warner so that its customers may also receive Lifeline assistance and customer protections.

New York’s Utility Project has emphasized that broad new regulatory  policies can only be adopted when meaningful strategies are developed to address the decline in telephone subscribership and the level of low-income customer participation in the Lifeline program