The City of New York (City) submitted initial comments and secondary comments that reiterate its previous concerns. Specifically,
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Altice continues to disregard the City’s authority - the City is dismayed that Altice continues to deny the City authority to review the transaction and the Franchise and Concession Review Committee authority to vote on the franchise transfer. The company claims that local review is not required. The City is alarmed by reports that SFR, (Altice’s French affiliate) has failed to follow through on commitments initially made to regulators and boasted about profitability by sacrificing both the quality of its network and customer service. The City is concerned about whether the company will, in fact, deploy fiber to the home and make other promised network investments. The City reiterates the importance of the Commission’s establishment of meaningful, enforceable conditions and ongoing oversight with respect to the concerns expressed by the City and others.
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Altice’s record in other jurisdictions suggests negative impacts for consumers – the City states that Altice’s performance history suggests that the acquisition could result in harm to New Yorkers. It notes that Altice has projected that the deal will result in some $900 million in “synergies” but has not explained how it will realize these savings nor the impact that reductions in spending will have on cable and broadband delivery, customer service or other matters. The City quoted expert predictions that, in light of anticipated cuts, customer service is unlikely to improve if the transaction is completed. The City’s Department of Information Technology and Telecommunications (DoITT) indicates that CV’s complaints have increased over the course of the last year. The City is concerned that Altice will concentrate investments in parts of the network that serve high-income communities outside the City while failing to invest in infrastructure in the Bronx and Brooklyn. This action would hamper residents’ access to cable television, as well as efforts to utilize broadband for health, educational, employment, entrepreneurial or creative purposes or to connect with family, friends and community members. The City wants the Commission to require Altice to commit to improve upon CV’s customer service record by requiring specific investments in training and personnel, to pledge that it will not provide substandard infrastructure in lower-income zip codes and to include enforceable penalties.
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Altice has failed to produce information and assurances to address City concerns; Altice has not provided sufficient information to enable analysis of its managerial, technical and financial capacity to manage the franchise or to provide answers to public interest questions raised by the City. DPS comments suggest that Altice has similarly failed to provide sufficient information to satisfy the state officials. In the absence of detailed information and binding commitments that are sufficient to address these concerns, this transaction cannot be said to meet the public interest standard.