The Communications Workers of America told the FCC the union’s review of...

justified. “The cross-marketing agreements and Joint Operating Entity (JOE) create a communications cartel with the market power to set prices, service levels, and determine the pace and direction of innovation,” CWA said in a filing redacted before public distribution. “The Transaction eliminates cross-platform competition, particularly in the Verizon landline footprint. The Transaction will lead to FiOS decline and an end to FiOS expansion. This will result in the loss of approximately 72,000 jobs. The Transaction makes it nearly impossible for the nation to achieve the National Broadband Plan’s goal of 100 million households with broadband access at speeds of 50 Mbps downstream/20 Mbps upstream by 2015.” CWA reiterated its calls for conditions, including the prohibition of cross-marketing arrangements in the Verizon landline footprint. “Verizon competes today against Comcast, Time Warner, Cox, and Bright House Networks with its DSL broadband service in many of its non-FiOS landline footprint service areas,” the union said. “Allowing cross-marketing in the Verizon footprint where Verizon has not yet deployed FiOS would serve as an additional disincentive to FiOS expansion.” CWA also called for “meaningful commitments” as part of the JOE “that would allow any competitor access to intellectual property necessary to compete so long as they are willing to purchase licenses under reasonable and non-discriminatory terms.” The FCC should also make Verizon offer FiOS service and expand in-region deployment to cover at least 95 percent of “residential living units and households” within the company’s service territory and “eliminate anti-competitive most-favored-nation provisions,” the union said.