Bad Metrics Make Bad Policy
Progressive Policy Institute
February 23, 2026 | By: Michael Mandel
The Progressive Policy Institute (PPI), a think tank that advocates for economic policies that are pro-worker, pro-business, and pro-innovation, cautioned the CPUC “not to rely on this flawed study to make any policy judgments related to broadband.” The study, which PPI says, “could have been entitled “No Digital Discrimination Found in California’s Urban Broadband Markets,”” makes “several fundamental mistakes,” including:
- Leaving important variables like population density out of the pricing analysis, resulting in potentially “spurious correlations between fewer providers at a location and higher promotional rates.”
- Confusing correlation and causation and omitting results that did not show the desired correlation between price and competition: “The report appendix notes that “Comcast is excluded from the regression analysis because its pricing strategy reflects large, market-wide discounts followed by secondary geographic variation that do not correspond to local competition intensity.” In other words, the Comcast regression did not show the desired results, so the report did not show it. In addition, the report acknowledges (note 37) that its regression analysis produces inconsistent results for Charter.”
- Ignoring 5G fixed wireless internet providers, such as T-Mobile and Verizon, and satellite providers, such as Starlink, which are available in many locations covered by the report and provide intense competition to wireline providers.
PPI concludes that the analysis in this report shows “providers do not systematically adjust promotional pricing based on income levels” and “we should take comfort that the increasingly competitive marketplace for broadband is benefiting consumers.”
Information Technology & Innovation Foundation:
January 30, 2026 | By: Joe Kane
Joe Kane, director of broadband and spectrum policy at the Information Technology and Innovation Foundation, said the Public Advocate’s Office “Broadband Competition and Pricing Strategies in California’s Urban Markets” report “doesn’t tell us anything about competition or the affordability of broadband plans that meet real consumer needs, rather than meet an arbitrary, impractically high number.” However, the report’s technical appendices show the price of sub-gigabit high-speed broadband plans in California often come in below $50 per month, less than the national average.
In discussing “Broadband in California: Pricing, Affordability, and Adoption Trends,” Kane noted the second report’s “lead finding on affordability [used] a tiny minority of plans used by less than 3 percent of Californians to claim statewide prices are twice as high as they really are.” In fact, the report itself acknowledges “average prices for broadband service have declined across speed tiers.”
Advanced Communications Law and Policy Institute
February 12, 2026 | By: Alex Karras and Michael Santorelli
Alex Karras and Michael Santorelli of the Advanced Communications Law and Policy Institute’s methodological review challenged the California Public Utilities Commission’s Public Advocates Office (Cal Advocates) report that concluded state broadband subscribers could save $1 billion if competitive pricing prevailed statewide, noting the analysis is “built on unrealistic assumptions,” and relied on an “outcome-driven model to yield supportive results.” One obvious flaw was that the “‘competitive’ benchmark use[d] the lowest promotional prices across multiple speed tiers, while the ‘monopoly’ price use[d] each provider’s highest 1 Gbps promotional price — an apples-to-oranges comparison that inflates the claimed harm.” Another flaw: Frontier, a major fiber competitor, was excluded from the pricing analysis “due to its ongoing merger with Verizon,” yet Charter and Cox—two of the three providers included in the regression—are themselves in a pending merger, yet neither was excluded on those grounds. And, notwithstanding the myriad other issues with the analysis, the study’s own regression results are inconsistent. The scholars’ methodological review of the report casts significant doubt on the report’s claim of consumer harm.
International Center for Law & Economics (ICLE)
February 26, 2026 | By: Jeffrey Westling & Kristian Stout
Jeffrey Westling and Kristian Stout argue that the California Public Utilities Commission’s Public Advocates Office’s “Broadband Competition and Pricing Strategies in California’s Urban Markets” report mistakenly equates healthy broadband competition with the presence of multiple overlapping gigabit-capable wireline networks. The authors contend that focusing on high-end, gigabit-tier pricing ignores how most consumers choose lower-speed, more affordable plans that meet typical broadband needs and show relatively stable prices regardless of gigabit overlap. The report’s competitive benchmark—derived from comparing premium gigabit offers in multi-provider areas with the highest gigabit prices in single-provider markets—leads to an inflated estimate of more than $1 billion in annual “monopoly rent.” In practice, only about 30 % of households subscribe to gigabit service, and most buy mid-tier plans, undercutting claims of widespread harm based on premium prices alone. The authors also criticize the use of temporary promotional prices rather than long-run effective costs and note that competition today includes cable, fiber, fixed wireless, and satellite alternatives that have helped push prices down. They warn that tying competition policy to arbitrary high-speed thresholds could justify restrictive regulations and block efficient consolidation, ultimately reducing investment incentives and slowing network upgrades and expansion, to the detriment of consumers.