After a long pause, the FCC’s review of the Comcast/TWC merger is back underway. Now, the wave of comments in response to Comcast’s last data dump are starting to roll in, once again asking the agency to block the merger.

Our colleagues down the hall at Consumers Union (the advocacy arm of Consmerist’s parent organization, Consumer Reports), together with Common Cause, are once again urging the FCC not to allow the transaction.

The comment (PDF) reiterates many of the arguments Consumers Union, Common Cause, and others (including we here at Consumerist) have been making against the merger for months. Among them:

• Competition is not as fierce (or extant) as Comcast claims. Mobile data (as we demonstrated) is absolutely not a realistic substitute for wired broadband, nor are DSL or fiber realistic competition in the majority of markets. And even Comcast isn’t sure that the merger won’t reduce what scant competition there is.
• The purported benefits of the merger aren’t that great. Comcast likes to talk about expanding their Internet Essentials program, which really has connected 350,000 families to inexpensive broadband. But there are millions more who are blocked from participating in the program, which still only provides a fraction of the service to low-income families that their higher-income peers can afford. And public and private entities should be working to close the digital divide even without the merger. Using low-income children as a bargaining chip is not a great look.
• A bigger Comcast is not good for net neutrality. Due in part to a coincidence of timing, the two issues have visibly gone hand in hand all year long. Comcast has strong incentives to double dip and to act as a chokepoint for data that travels to their customers.

And of course, Consumers Union adds, taking competition to a level even worse than its current abysmal state will do no wonders for either pricing or customer service. Consumers who don’t have the ability to change providers (so, nearly everyone) will just have to take what rapidly increasing prices and legendarily awful service they can get.

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