If the proposed merger between Comcast and Time Warner Cable is approved, the two worst-rated internet service providers in the country will join forces to become the “largest media, cable,
and internet company in the world,” warns City Public Advocate Letitia James. In New York, it could mean that low-income New Yorkers, who already have limited access to an essential service, could face increased costs with fewer options for internet.

“There is an urgent need for the deployment of high-speed internet in Staten Island, Brooklyn,
Queens, the Bronx, and Northern Manhattan,” writes James in a new report about the potential merger’s effects in New York (PDF). “Nearly a third of the residents of New York City do
not have access to broadband.”

Both the FCC and the DOJ are reviewing the merger request, and in New York, the Public Service Commission will evaluate whether the merger serves public interest. James’s report lays out the merger’s effects in NYC, and asks the PSC to consider a list of recommendations of conditions to impose on Comcast should it approve of the acquisition.

The biggest issue James sees with the potential merger is that there are very limited options for New Yorkers who can’t afford to pay premium prices. While Comcast does offer an Internet Essentials package at $9.95 a month, the service has several problems with it:

First, in order to enroll in Internet Essentials, the consumer cannot have subscribed to Comcast Internet Service within the last 90 days. This is a major barrier to affordable service because it forces consumers to go three months with no internet during which time they could be applying to jobs or accessing vital programs and services. The second barrier is that Internet Essentials is separate from Comcast’s standard service. It uses a separate website and phone number for enrollment and information increasing the risk that consumers will not be redirected to the program’s phone or website if they contact Comcast directly. Finally, the program offers 5 Mbps download speeds and 1 Mbps upload speeds, which according to Slate is only “good enough for basic browsing.”

To better serve low income communities and ensure that everyone has access to internet, James wants Comcast to offer universal broadband in the city; invest and improve the city’s broadband infrastructure; improve its poor customer service; offer free Wi-Fi in all city parks; and offer “free access, training and equipment for all public housing residents of the New York City Housing Authority, all senior, youth and community centers, and all domestic violence and homeless shelters.” She also wants Comcast to improve its offerings under the Internet Essentials package by boosting download speed to at least 10 Mps; offering discounts to small businesses and incubators; and removing connection fees “in communities that do not have existing cable services.”

James has been a vocal critic of the $42.5 billion dollar merger for months. Upon the release of her report, she told Ars Technica that while “The jury’s still out” on whether the merger could benefit consumers,” she remains skeptical. “I’m concerned about creating monopolies, I’m concerned about unequal provision of service, I’m concerned about increased cost,” she said.

(Photo: Mike Mozart)