 Hello. Welcome to our public knowledge 20th anniversary event. This is the fifth in a series of events that we are having to celebrate the 20th anniversary of public knowledge and our commitment to serving the public interest. I'm very pleased to be hosting this panel on the future of voice, not so legacy after all. We talk about legacy and the legacy networks, but the fact is that voice is and remains a critical service. Public knowledge, although we are focused a great deal, of course on broadband, we have been very active in protecting voice communication resiliency. This includes everything from competition and mobile wireless to network resiliency and reliability. Starting in 2012, 2013, a combination of the FCC's consideration of how to phase out the public switched telephone network, the PSTN, and the results of Superstorm Sandy prompted public knowledge to become involved in what was at that time called the tech transitions, which is the name given to the general transition of wireline services from the traditional circuit switched copper based network to IP based networks. Over a variety of media, some of them, you know, copper hybrid fiber coax fiber, and we then had a lengthy FCC proceeding spanning a number of years where we public knowledge argued that this transition needed to be based on a set of fundamental values that this shouldn't just be innovation for innovation's sake, or focus on, you know, what the cost savings that can come from IP transitioning to IP networks but that in the United States we have had a long tradition of incorporating fundamental values into our communications policy starting with the post office at the founding of the Republic running through the telegraph and the telephone. These include universal service, competition, consumer protection and public safety, and we had a proceeding at the FCC. I will say after many years we were successful in working through a set of rules to govern the transition in wireline, which were designed to preserve competition and to continue to protect consumers and maintain universal access to voice service in all of the United States. Unfortunately, the Trump administration saw things very differently and ran through a set of proceedings that effectively repealed all of the safeguards that were put in place and allow the carriers with their legacy voice networks to retire the copper networks with fairly minimal obligations and a fairly minimal showing that there is at least some potential service in the area that they are discontinuing. In the meanwhile we have, so that transition is in fact ongoing, we have seen, some of you may have seen AT&T announced that it is discontinuing its plain DSL service as part of this transition, but this is all part of their general retirement of their traditional copper network to be replaced in some part with fiber, but in other part with a mobile service package that can be attached to the house. Other carriers at various paces are similarly retiring their copper networks. And one of the things that we will discuss and get into with this panel is how that is working out, particularly for rural America and vulnerable populations. It's important to recognize that we still have a significant number of people, about 30 million or so who are still dependent upon copper lines. That's a small percentage of the market compared to what it was 20 years ago when everybody was dependent on copper lines, but that's still an awful lot of people. Many of these people are part of vulnerable populations, the elderly, in rural places where there is spotty cell coverage, in poorer communities or communities where there is significant risk of natural disaster and people want the self-powered copper lines. So there are a lot of issues that we will be talking about there. And in addition, we are seeing the phase out of the 3G wireless networks, what is called the 3G sunset. This is an area where cell phone companies are retiring their older networks. This is part of the standard wireless process. There's a limited amount of spectrum and older networks become more expensive and difficult to maintain as people stop making the parts. The natural cycle of people replacing their phones is one that lends itself well to gradually moving people off of the older network onto the newer networks. But the networks are still being used. This is the first time that we are engaged in a transition and shutdown of cellular technology where we have not had any sort of FCC involvement or oversight. This is, at the moment, at least entirely industry driven. And we are seeing already a lot of concerns around that. The alarm industry has filed a petition with the FCC asking them to require AT&T to slow down its shutdown, which is scheduled for the end of this year because they have many alarm systems that are still dependent on 3G network, that they haven't been able to upgrade as a result of COVID and chip shortages. There is a dispute between Dish and T-Mobile over T-Mobile's plan to shut down the Sprint 3G CDMA network, which forms the basis of the boost network that Dish acquired as part of the T-Mobile Sprint deal. There are a number of concerns about that and a lot of back and forth. That's currently being reviewed by the Department of Justice and the California Public Utility Commission, but not the FCC, which has not elected to become involved. So we have a lot of transitions going on over the voice network, which is really the core of what the FCC was formed to do. And at the moment, not a lot of FCC oversight or involvement. So that raises a number of questions. We have a panel of experts here who we will discuss this with. If you have any questions, please use the Q&A section at the bottom of your screen. I will run through some introductions now and then I will proceed to ask the panelists a number of questions before we get to questions from the audience. But again, if you do have questions, you can enter them in the Q&A at the bottom of your screen. Just click on that. You can type in the comment and hopefully we'll have the opportunity to address those. If you have in mind somebody specific for the question, feel free to say so, but all questions are a fair game for everyone. I will also mention in what is perhaps an important example of the ongoing importance of voice and the problems of broadband connectivity in this country. Craig Settles, who is one of our panelists who specializes in rural communities has dropped off for technical reasons and is trying to dial in. So hopefully he will be able to join us if he does just so I don't have to pause to introduce again once he's here. Craig Settles conducts needs analysis with community stakeholders who want broadband networks to improve economic development, healthcare, education and local government. Since 2006, Mr. Settles has provided community broadband consulting service. He hosts the radio talk show Gigabit Nation and is Director of Communities United for Broadband, a national grassroots effort to assist communities launching their networks. He is the author of the book Building the Gigabit City and writes a blog of the same name and looks like he is actually now able to join us by phone and so thank goodness for voice communication after all. Also with us today are Nell Geiser. Nell is Director of Research for the Communications Workers of America, where she coordinates the Union's telecom policy initiatives to achieve universal affordable broadband access. Nell has worked in the labor movement for 15 years and is a chartered financial analyst. CWA represents telecom workers nationwide at AT&T, Verizon, Lumen, Frontier, Winstream, Consolidated, Cincinnati Bell, Altis and other providers. And finally, we have the Honorable Mignon Clyburn. Mignon Clyburn served as an FCC commissioner from 2009 to 2018, including being the first woman to serve as acting chair or chair in any capacity from May 2013 to October 2013. Before that she served 11 years on the South Carolina Public Service Commission and with chair from the South Carolina PSC from 2002 to 2004. Today she is the principal of MLC Strategies LLC. Full disclosure among her clients are T-Mobile and Encompass, which is a trade association for competing telecommunications carriers. Thank you all very much for joining us today. Let me start with a question to Nell. So CWA worked very closely with public knowledge on the tech transition proceeding and the transition of wireline networks. We had a lot of concerns. We thought we got a fair number of them addressed until the Trump administration reversed them. We're now three years into the deregulated tech transition. So can you talk about what some of the biggest issues are, both in terms of, you know, what's happening now on the ground? What are we seeing? And what are we worried about happening going forward? Thanks, Harold. Yeah, CWA is very attuned to the ways in which a transition from a legacy system of rate regulated incumbents to a deregulated market based system presents serious risks to the public welfare. And as with the 3G sunset that you talked about, some of the most vulnerable populations may be disproportionately impacted. That would be older people, lower income households in rural and urban settings who have not upgraded or do not have access to new technology. A shrinking share of the market, of course, relies on copper plain old telephone service. But, you know, while it is being gradually replaced, the replacement is not happening at the same speed for everybody. And so there's a lot of impacts around people's individual safety and security, you know, also the ability of small businesses to operate due to the various equipment impacted you talked about the alarm systems. So certainly there are serious public interest concerns when it comes to the retirement of copper networks, whether it be formal or de facto and we strongly agree with public knowledge that principles are needed, along with enforcement of those principles to ensure that some parts of the country are not left without essential communication services. We do see that with AT&T's DSL retirement and the general deterioration of the copper plant among the incumbent local exchange carriers, that there certainly are cases where people cannot, you know, call 911 where folks are not able to get a dial tone after a storm. And then when they're trying to order replacement service, it's not available to them and where they are they're being pushed to wireless solutions that are not adequate. So, so we hear about those those instances from our members and, and the principles that were established in the good IP transition rules under Wheeler that have been significantly weekend weekend would require attention to a number of issues when transitioning to a new technology service. So, you know, just to add a little bit to what you already covered there's network capacity and reliability, there's service quality, there's device and service interoperability, which gets to some of the, you know, the equipment that needs to be replaced. Accessibility and service for individuals with disabilities, emergency communications capability cyber security service functionality, again with, you know, being able to interoperate with all the necessary equipment and coverage so there's a lot of everyone impacted by a retirement so these rules would require a functionality assessment where where there's been an allowance for the network to de facto retire, you know, not just a formal petition for retirement and that's one of the things that was removed in the beginning of the rules. So, you talk a little bit more about that de facto retirement because that's kind of a, you know, term of art that I'm not sure everybody listening will know what that means. But de facto retirement means that there's a failure to maintain the copper loops or sub loops or the feeder portion of such loops or anything that is, you know, functionally equivalent to removal or disabling of the network. And so when a cross box or a, you know, copper cables are allowed to just kind of hang out of their casing and are chewed up by rodents and are not properly repaired after storms or just wear and tear. It really is a de facto retirement of the network and that's happening very broadly and we've documented it our members have documented that in the field across the country and of course it's understandable that Ilex, you know, our phasing copper networks out, given the environment that we're in cable has leapfrogged them on market share without having the burden of having to provide universal service, but you know, it's also really a tearing of the social fabric and the social contract and I hope that that the free market will catch this free fall and, you know, in our extremely unequal society where so many working poor people cannot afford broadband and the existing subsidy programs are inadequate that we can talk about but, you know, our members who maintain telecom networks see themselves as the stewards of universal service but we're really in this environment where carrier of last resort which is what has historically applied to the copper networks is a concept of the past and so that carrier of last resort is when the I like leaves town and when the state strikes down carrier of last resort from the statute says as you know half have, you know what what standards of service will the default carrier be expected to meet who's going to share after the I like leaves the fantasy that of multimodal competition that is promoted by many industries not really a thing it's it's a fact that fiber to the premises is by far the best solution for the vast majority of the country so that's what you know we're doubled down on supporting in the federal infrastructure push and we need a policy that really supports fiber deployment and holds providers accountable to deliver you know the speeds and technologies they promise by we're advancing model state legislation to regulate broadband under public utility commission authority and in specific areas of public safety and network resiliency consumer protection. So you know I think just to tie it all together that IP transition is really a test of our social contract for communications and so far we are failing. So thank you, you know, both for your, your work on this and and for your, you know, answer there, even if, you know, as you say we're so far we are failing to live up to our social con act so I want to switch now to Craig and talk a little bit about the 3G sunset. Sorry, I got muted there let me just Craig there's always been a worry in rural America that there hasn't been sufficient wireless coverage but there does seem to have been at least more 3G coverage than 4G or 5G. So what is, what are the concerns that we're hearing from rural America about the 3G sunset and how should folks in rural America be preparing for this. So it seems that the problem, well there's several problems I guess, but to me as a marketing person, I think one of the biggest problems is that it doesn't seem to be a lot of coverage about the sun setting. I've done some Google searches and looking for information. I don't see any articles in any of the major tech pubs, not the business pubs and so forth. And so, I think that that is a problem in itself. I mean, if you look at other transactions from one technology to another like going when we went from analog to digital TV, you know, it was like you couldn't, you know, unless you were in a cave, you knew about the particulars of the transition. And actually until you send me a note, I had no idea that there was a transition. And if that is the case throughout rural America, you know, I dread to see what will happen when it's next to, you know, this like November of next year, and no one has been fully prepared for the change. So I consider that like the biggest problem right now. I mean, maybe you can tell me that there's there are other places we have seen articles or webinars or what have you, but right now just seems pretty barren on that topic. Well, yeah, I mean, I would say that other than the T-Mobile dish fight, which has gotten some coverage in the trade press, there hasn't been a lot of, you know, sort of general coverage of what's going to happen and how this is going to work. And I know that T-Mobile had an announcement, I think last month, where they issued a press release and made a corporate announcement that about their plans and how, you know, their subscribers could, what their subscribers should do. There isn't, you know, we're a rare breed who think that corporate telecom websites are fine reading and, you know, have alerts for that on the web. But let me turn now to Minyon Clyburn, especially because, you know, as a commissioner during the tech transition, you were a real champion on this education point. And this was something you fought very hard for and, you know, we're out there that we needed to, the commission needed to have money budgeted for this, the carriers needed to, you know, have outreach in the same way that we did for the DTV transition. So what role do you think now, you know, the FCC ought to be playing and not just, you know, for the tech transition, but also for the 3G sunset is the FCC right to let the industry just lead here and have a hands-off or is there some role, even if it's just educational, promotional, letting people know that this is a thing? Well, thanks so much, Harold, for having me. I have to pause and say it's an honor to celebrate 20 years with an organization that has never backed down from a fight and has always had the consumers back. And one of the things you remind me of the not so distant past where a former commissioner not only, though she cannot recite every word in the 96 Telecommunications Act, she lived it. And I fought hard for what you mentioned and competitive competition policy and those protections to remain in place because we made a promise that was codified in 96 that there will be competition and there will be protections. It was forecast these evolutions and revolutions in terms of technology, platforms and options, but we did not tell the American people that we would just leave them alone. So the FCC, as a part of its poor part of refrain to include public safety, has a consumer protection obligation that regardless of how we communicate, if it's by voice, like Craig, or if it's, you know, over the airways like we're doing now and hopefully will last this entire segment, regardless that there is a backstop there is an authority there is an agency that will look out for your interest. So, again, technologies change but our obligations to the American public meaning our the FCC's obligations that remains the same. So, you know, there is no negotiation when it comes to that. Right. So, you know, that's, you know, it, first of all, it's always wonderful to hear you talk about this, and, you know, the same passion that you brought as a commissioner and acting chair. But let me open this to everybody about the general importance of voice I mean we're sort of oddly lucky to see this with Craig's technical difficulties but you know there have been people who have said well we should not have universal service fund the lifeline program, which for folks who are unfamiliar goes to help subsidize those who are to poor to those who are at 133% of the poverty line makes them eligible for a subsidy. Traditionally it's been for phone, we've had efforts to include broadband in that now we're talking about, you know, making that available for broadband but they're also those who say well, you know, just make it available for broadband and not for voice that we don't need the voice network that they are in fact as part of their repeal of the tech transition protections. The Trump FCC said well as long as there's a broadband provider in the area that's capable of supporting a voice application that ought to be good enough so let me put that to the panel is is is voice just yesterday's news is there a reason why we still care about the voice network. Let me go back to a couple of things, number one, what now mentioned, because I think she set the stage for that question I don't know if you guys work together, but one of the things that that we need to be conscious of is there's a lot of uneasiness and evenness and you know in this nation, not all communities are created equal, not all infrastructure, you know, in terms of availability and access that is not all even or the same. So, to me, when it comes to connecting, you know, our communities, it's layered, not taken away, it's adding on options, you know, not taking away the fundamentals, because many on cyber prefers to speak over the phone as opposed to text. You know, minions neighbors, you know don't all have broadband they can all afford it. When we talk about our public safety obligations, you know at the FCC and in this, you know, nation, you know, first responders still need a voice connection in order to serve the, you know, the public. So we have to keep in mind that it is truly an all of the above inclusive type of, you know, obligation, and I believe, you know, options, you know that we have in order to keep our communities connected. It is not a trade off that we make. It is allowing for layers, you know, of opportunities. It is not making something like voice obsolete. It is ensuring that there are other compliments, you know, to voice, because defaults in this case, in order for Craig to speak with us, I mean, it is proven it proved its values in the first couple of minutes of this of this panel, that voice is a thing must be enhanced, you know, through these advancements, not taken away not ignored not discarded. Yes, that's that's an excellent point and I'll mention also that voices the technology where we had 98% penetration for the American people, you know, and I don't think we've had any technology, any voice any communications technology, certainly not a two way rather than broadcast technology that is achieved that kind of penetration ever. So let me ask now any anything to follow up on this and, you know, specifically about universal service and you know should it continue to support voice and or should we just shift it over to broadband. Yeah, the voices is very necessary for safety accessibility and greater reliability in some cases like with Craig's experience wireless voice service in rural areas is often much more reliable than data service. So a lifeline subscriber survey in summer 2020 found that when asked which services lifeline subscribers valued most more than two thirds of subscribers value voice text and data services equally so I think that's a really important point. And those respondents are sort of clearly pointing out that data has become equally as important, and there's a false dichotomy between voice and data, which will eventually need to be breached but for now we need to recognize that voice still serves this unique purpose and has unique protections that should be maintained and built upon and, and so the FCC did recently open a docket to refresh the record on an Asuka petition that consumer advocates opposing the lifeline orders under pie that would have that would phase down subsidy support for voice and really just focus on data, and there's a lot of opposition to that from advocates and providers. And so it's timely that the FCC is refreshing the record on that. There was also some interesting commentary at the Minnesota PUC this week in a docket where lumen is petitioning to eliminate service quality rules for voice and, you know frontier said in support of lumen that they experience the same demand to prioritize voice over broadband service in order to comply with these service interruption rules so they're saying that the Commission is unfairly forcing them to maintain voice at the expense of broadband investments which is a, you know, a false trade off they're trying to put in front of the Commission and lumen says that the 40 year old rules here are quote reflective of an era where providers were monopolies that could recover costs associated with service quality standards through rate of return pricing, and it expressed concern about balancing the importance of voice and broadband service in Minnesota. So, you know this is basically them saying we shouldn't have any telephone voice regulations because we don't have any broadband regulations. So it's it's speaking out of definitely two sides of their voice but the Ilex also have a very logical position you know that they just operate on illogical terrain. And so these services voices writing over the, the same network as data now in a lot of cases and states have a strong interest in ensuring that the network functions for all subscribers and that same for the pure play broadband ISP so definitely to maintain it in lifeline. Glad the FCC is looking at it again. And, and, and the reforms that came under PI were really aimed at weakening lifeline not making the fixes that are needed to enhance and and broaden the base there. Great. Yeah. Oh, I'm sorry. Oh, I'm sorry. Yes. I did want to bring up one thing that I know could get lost in the shuffle, which is any type of vital service that is relying on the 3G network could get lost in the shuffle. For example, metal art is a service that particularly used by seniors. And if all of a sudden that goes away, you could have some serious consequences because what's going to replace that, or what are the providers of metal art or how are they going to even know which of the customers that are on the network, the 3G network, how would they even know or how to get to those folks, you know, because some of that information that contact information may be held by the carriers, but not these, you know, these offhand service providers. So, you know, what, what is, you know, and, and maybe, maybe you have an idea, Harold, but how are we going to address that need. And, you know, people have a lot of short term memory loss here. You know, again, what is layered or dependent on the other, you know, when we talk about the, you know, pointing when it comes to voice or being dismissive, you know, think about the innovation that has occurred, how that smaller players that introduce Ethernet VOIP cloud and one call connect all services, how those enterprises have reshaped the industry and improve service for consumers and businesses. That just doesn't go away with, you know, the new and more shiny. You know, again, we keep picking on Craig today, but the legacy, you know, systems and the significance of them prove themselves time and time again. And I just firmly believe and I have to know that the FCC believes and it has to continue to balance and craft policies to ensure that, you know, things are complimentary that tradeoffs are not made. You know that these are building blocks, it's not exclusion, you know, that should be that rules that should rule today. Yeah. And, you know, just to, you know, what two interesting facts contributed by Richard Chalky in our Q&A, which is that number one, the FCC data indicates the voice services holding steady for a total number of minutes. So clearly this is a service that people are using and continuing to use and the availability of other services like video conferencing is not a replacement for voice. He also points out that 80% of voice right now runs on the IP network and I think nobody disagrees that the future of voice is IP. What I think everybody has focused on here is that as we plan for that future, we're not replicating the features of the old network that made it something that was universally and affordably available to everyone that were not, you know, maintaining the reliability of it with disastrous consequences for public safety as well as for just the quality of communications and how that impacts but, you know, you won't hear anybody say that we want to keep legacy copper up. The point is, as public knowledge said, you know, consistently, the, you know, we want this to be an upgrade for everyone, not an upgrade for all for some and a downgrade for others so thank you Richard for those contributions. I have also a question from Laura Taylor I'd like to address to the to the panel here. Are there any national findings that speak to the need for an analog safety net during emergencies or disasters. What are the vulnerabilities of broadband networks versus analog networks during emergencies and disaster, and how important is this redundancy. And I'm glad he mentioned, you know, now is probably better at the, you know, the statistical statistical analysis, but I will will say that, again, the times have proven themselves over and over again about, you know, resilience and redundancy. And I say a part of that redundancy, you know, equation includes voice. It is, you know, a redundant complimentary feature that should be maintained because systems ultimately fail, we need back stops we need compliments in order to ensure public safety and other forms of communications. You know, if my internet goes down which it has, and I need to speak to my medical professional, I'm going to pick up the phone and when my doctor told me that I needed a certain, you know, medicine that he knows I'm not going to take anyway. He did not, you know, you know, say Mignon, you know sign into zoom, he called me, and I needed that type of reinforcement and I didn't want him to see the expressions on my face, because I knew I wasn't going to take what he prescribed. So, you know, these are the type, you know, that's just, you know, a quirky real world example, but to me, you know, it should best illustrate that we do want hard and more resilient. We, you know, networks, we do want to get rid of the things that are outdated. But we need to be careful about what that definition of outdated means that doesn't mean that voices outdated those platforms outdated. It would mean, could mean that some technologies like that 3G phone respectfully that you might not be able to talk and stream at the same time, or, you know, that may or may not have certain 911, you know, capabilities that consumers expected me those protections for public safety that that might not exist. I'm not talking about that, but voice is critical. And to even be dismissive of the most consistent and as you said most ubiquitous form of communications, the ability for us to continue that. I think is wrong headed. I would want to go ahead. I just want to add that. Yeah, I think it's less about analog versus digital and more about redundancy I've heard from our members about the lack of redundancy around having fiber rings in place and other kinds of backup for one a particular part of the network. For example, a fiber cable is cut, you don't have adequate backups in place and similarly there's not a set of standards around backup power for the, you know, the broadband networks, though that California is leading the way on that and so there's a need when we don't have a self power and copper network to ensure various forms of redundancy and backup power to deal with emergencies and outages will be really important and are lacking today. I just want to stress this about power because a lot of the talk about power including in California is about power to the cell tower. But we have to remember that, unlike the traditional copper network where the connection to the home was self powered IP networks can't do that so we right now have simply a requirement that at the federal level that when you switch to an IP network, the provider has to offer you one time at the point of sale backup power availability for eight hours. And, you know, that, you know, that was not, it was tough getting that in 2015 and, you know, many of us considered it inadequate at the time. There's a lot of concern actually about whether providers are complying even with this minimal requirement but certainly it's something that whether it's mobile technology or landline IP technology. The need for backup power to the home, not just to the, to the tower is something that is absolutely critical and that a lot of people, including embarrassingly some power companies don't seem to have realized how important all of that is. I do want to ask competition question because we haven't had a chance to get to that yet. You know, we get, you know, well, competition is an important value on the wire line side you have companies like, you know, Sonic and granite that have used access to copper to build out competing networks. And we have a lot of MVNOs, or a lot fewer than that we used to have but we still have on the wireless side. There are a lot of, and a lot of carriers still use 3G networks for roaming for voice because that's a much cheaper network for voice and frankly in rural areas you get the, there are oftentimes a lot more towers deployed on 3G. Yeah, then there are radios that are 4G or 5G. So what are the concerns here about whether the tech transitions are going to be serving competition and what, you know, how do we take advantage of this moment of transition to actually help stimulate the competition if we can. I have a question, I guess. We're, we're can citizens make an impact on these kinds of discussions like we're talking about competition right so everyone in, you know, our circle knows and understands that competition is necessary. And the lack of it is why we have so many problems that we have in broadband and voice and whatever, but how does the, the communities, how do they affect change. And I look at Ohio, for example, where the incumbents tried to slip a band on all things related to municipal broadband. Right. And so, luckily, the various activists within the state rose up and defeated. Right. But I often wonder, you know, do people have an out and away that enables them to affect the type of changes that we in this, you know, this kind of circle advocate or, you know, support. I think you, I think you will increasingly see, you know, communities and Hamlet's really not only speaking to their needs, but proposing different types of public private partnerships to meet those needs. So I can think of, even though we have very restrictive laws in my home state of South Carolina, you've got, you know, what they call Internet cooperators so some of the electric cooperators that are really pushing the envelope been in working with nonprofits and other communities and demanding more digital parity at home. So you're seeing states hiring more CTOs and broadband, you know, officials that are really addressing and are being more transparent than ever before about where the problems are what they need and certain price points. So what I am seeing on the ground is a very bold attitude and more demands of state legislators and a little bit of retreat with some of the laws, you know, that have been in place in, I think, 30 some odd states, you know, pushing back like you saw, you know, in Ohio that if the incumbents will not, we will find a way to. So I really think increasingly you're going to see not just the activism, but the actions, you know, to spur this type of the examples like you see with a granite, you know, you saw a disconnected market and went after it and the sonic was offering gigabit speeds for $40 a month. All you need are, you know, a few examples and other jurisdictions and others will either follow or will push their, you know, their lawmakers or regulators to enable the same. I would point to the, the middle mile initiatives that states are also developing because I think some of what Harold you're referring to is a wholesale approach to competition and making existing physical networks accessible to competitive carriers of various kinds, whether it be the NOS on wireless or a future kind of select that would be more along the broadband type of things. But I think competition has failed to achieve universal affordable service, it has been a grand experiment of 25 years that has also been hamstrung by the rollbacks and court battles that have kind of undermined the intent of that original wholesale competition vision that Minyeon talked about trying to, you know, preserve at the commission. And so, you know, if we don't have a system in which there's protections of the public interest or protections for wholesale competition on these natural strategic physical networks, we're shooting ourselves in multiple foots. So, I'll just say, you know, from our perspective of public knowledge we view competition as a value, you know, for its own sake, not because it, you know, provides a lot of benefits to people, and not as an excuse for inaction by regulators to protect consumers of universal access. We don't, you know, depend on, you know, a hammer to do the work of, you know, saws and screwdrivers. We shouldn't depend on competition to do work that competition is just simply not suited to doing. But that said, you know, where we can achieve it and how we can encourage it is vitally important. And I'm glad you mentioned that because I was going to go back home again and affirm that an activist FCC is needed more than ever before. The agency as you know has a vital role to ensure that consumers will continue to be served, regardless of what phase in the transition we are that they're competitive. You know, that's part one of the four refrains right in terms of, you know, competitive options ensuring that we have access to advance, you know, services, you know, public safety. The commission cannot afford to be passive. It should monitor and serve that as that safety net that regulatory safety net, if problems arise, and it should address various to competition. And to me, the last thing I will say this and I've been saying this for a while. Everything we do should be needs base with the monies that we're talking about the billions of dollars in terms of expenditures, that should flow to where the needs are greatest, not where the politics are best. And so, you know, I'm just, you know, I'm taking off my consultant hat and putting back on my, you know, regulatory public interest hat that again, when we talk about the public interest and agencies, government agencies that help facilitate the public interest, we need to, you know, cast certain things aside, and really address the needs of those who are on the wrong side of the digital divide, who are vulnerable and a whole host of ways, and ensure that these transitions help identify the positive, but not take away things that are critical like voice that I think are not only a public safety necessity, but a mental and physical necessity to. I were at five minutes to the end of the hour. And, you know, I, I think that was an incredible way to close things out, but I will just add that I think a lot of the problem right now to go back to Craig's original question and actually the first point that Craig made is that this stuff is happening in shadows. Not, you know, that it's not covered by, by the press, people don't know about it. When you, when you tell people about it, they get very angry. And where people are losing connectivity, they're like, what the hell, you know, why, you know, my parents were able to make, you know, phone calls every day and they got through how did we get to be, you know, worse at this rather than better. At this and the answer is because we've made bad policy choices. So, I want to thank everybody here for coming and the work that you have done now all of you and continue to do. And I just want to say, this is one of a series of events that we are doing to celebrate public knowledge is 20th anniversary year, we've been pleased and proud to be part of the public interest community and fighting for the public interest agenda. Here in Washington DC, and our next, our next event, I think we have a, a graphic here on emerging technologies in July 2021. So, again, let me just say, thank you to all three of you, both for the work that you continue to do and for joining us here today and thank you to all of you who participated here.