As I discussed in an earlier post, the Consumer Federation of America (CFA) recently released a paper by its Director of Research, Mark Cooper, which made the case that the FCC’s decision to deregulate special access in 1999 was premature and has resulted in large-scale economic harm, including an estimated $150 billion over the past five years. Cooper’s analysis focused on two elements of harm: 1) the direct cost associated with non-competitive excess-profit-extracting pricing and; 2) the indirect economic costs associated with this pricing regime.
As it turns out, a few days after Cooper presented an overview of his analysis at a New America Foundation event, a paper was published by Economists Inc. Written by EI principal Hal Singer and, according to its cover page, funded at least in part by USTelecom, the nation’s ILEC trade association, the EI paper approached the issue from a different perspective, as explained in its executive summary:
This paper seeks to model the likely impact of the FCC’s recent effort to preserve and extend its special access rules on broadband deployment, as telcos transition from TDM-based copper networks to IP-based fiber networks to serve business broadband customers. The deployment impact of expanded special access rules can be measured as the difference between (1) how many buildings would have been lit with fiber by telcos in the absence of the rules and (2) how many buildings will be lit with fiber by telcos in the presence of the rules. With an estimate of the cost per building, the deployment impact can be converted into an investment impact. And with estimates of broadband-specific multipliers, the fiber-to-the-building network investment impact can be converted into job and output effects.
The executive summary also highlights the study’s key findings:
In the absence of any new regulation (the “Baseline Case”), an ILEC is predicted to increase business-fiber penetration… from 10 to 20 percent over the coming years…Next, we model a scenario where special-access price regulation extends to the ILECs’ fiber networks. Assuming this scenario reduces an ILEC’s expected Ethernet revenue by 30 percent—the typical price effect associated with prior episodes of price-cap regulation and unbundling—the model predicts that ILEC will increase business-fiber penetration from 10 to 14 percent (compared to 20 percent in the Baseline Case)…Thus, the special access obligations under this scenario result in a 55 percent reduction in an ILEC’s CapEx relative to the Baseline Case….Thus, expansion of special access price regulation to Ethernet services is predicted to reduce ILEC fiber-based penetration by 67,300 buildings nationwide—a result that is hard to reconcile with the FCC’s mandate to encourage broadband deployment.
Singer then considers the spillover effects of this reduced ILEC investment in fiber infrastructure. Using “a jobs multiplier of approximately 20 jobs per million dollars of broadband investment” and “a fiber-construction output multiplier of 3.12,” Singer estimates the resulting economic harm of FCC special access rules to be an annual loss of 43,560 jobs and $3.4 billion in economic output over a five-year period.
It’s worth noting that Singer’s estimate of $17 billion in economic losses over a five year period due to imposition of special access rules is considerably lower than Cooper’s estimate of $150 billion in economic harm from the unregulated status quo in today’s special access market. While Singer and others will likely take issue with Cooper’s assumptions and estimates, the latter’s paper seems to, at the very least, make a strong case that the economic benefits and harms associated with different special access regulatory regimes don’t only flow in the direction analyzed by Singer, and that policymakers would be wise to carefully consider a full array of harms and benefits associated with alternative regulatory approaches.
An opportunity to explore new policy, funding, ownership models
My sense is that both of these studies raise valid points about the types of economic harm associated with different approaches to (de)regulating special access (and other telecommunications) markets.
I also believe that valuable perspective on this issue can be gained from a review of of ASR Analytics’ estimates of economic benefits resulting from BTOP investments in fiber infrastructure (some of which I discussed in a recent post). Not only does the ASR study do a good job of applying prior knowledge and accepted methods in analyzing broadband-related economic impacts, it also suggests to me that, rather than getting caught up in the details of the Cooper/Singer and related debates, a more useful approach is to take a step back from the quantitative details of these dueling studies, and consider broadband public policy from a “public infrastructure” perspective.
In a follow-up post I outline a research project designed to build on the knowledge base developed by ASR’s study of the Comprehensive Community Infrastructure (a.k.a., “middle mile fiber”) component of the BTOP program.
In addition, I’ve prepared several other posts that try to explain some of the threads of scholarship that inform my own view of how—especially in cases lacking sufficient competition—special access and last mile access networks can deliver the most social value if treated as public infrastructure.
An annotated list of links to these posts is provided below. I’d encourage anyone involved and/or interested in policy debates related to issues such as special access, community broadband, network neutrality and universal service to review these posts and perhaps also explore the sources they refer to:
a) the relevance of Modern Monetary Theory (a.k.a. Functional Finance) to policymaking related to federal financial support for investments in telecommunications and other infrastructure;
b) the demand-side analysis of infrastructure resources laid out by Brett Frischmann in his 2012 book, Infrastructure: The Social Value of Shared Resources, and the Internet- and telecom-related policies it suggests;
c) the analytical framework developed by author Marjorie Kelly in her book Owning Our Future, which highlights key differences between what Kelly refers to as “generative” vs. “extractive” ownership models. One post reviews Kelly’s key concepts and considers AT&T as an example of extractive ownership of telecommunications infrastructure. A second post considers how Kelly’s framework applies to the role of community-owned broadband networks in the Internet access sector, and suggests research questions related to this that I believe are worthy of further investigation.
During the past few days I’ve been: 1) reviewing the BTOP program evaluation study’s final report prepared in 2014 by ASR Analytics and; 2) doing some homework aimed at better understanding issues related to the FCC’s pending special access study and proceeding. The former relates to a pending Quello Center research project, while the latter was prompted by release of a paper written by Mark Cooper, Director of Research at the Consumer Federation of America (CFA). Cooper presented the paper, entitled “The Special Problem of Special Access: Consumer Overcharges and Telephone Company Excess Profits,” at an April 5 event sponsored by the New America Foundation.
In his paper, Cooper made a theoretical and empirical case that “large incumbent telephone companies have engaged in abusive pricing practices” for special access services that have resulted in economic harm exceeding $150 billion over the past five years:
Today, special access is a $40 billion per year business, which works out to about $300 per household, which is almost equal to what they spend on landline telephone service…
This paper shows that about half of the total bill paid to the large incumbent local phone companies for special access service, who control between five-sixths and nine-tenths of the special access market, is the result of the abuse of market power – i.e. setting prices far above costs to earn excess profits…
Because of the importance of special access as an intermediate good, the $20 billion in annual overcharges suppresses a significant amount of economic activity, reducing economic output by at least another $20 billion. The magnitude of the harm has been growing steadily, so that the cumulative value of economic losses over the past five years is in excess of $150 billion.
While there’s much to consider and debate in Cooper’s analysis and, more broadly, related to the FCC’s pending special access proceeding (something that may be done in the future by me and/or MSU colleagues on this blog), for now I’m only going to use Cooper’s general argument as a jumping off point to consider a few metrics that struck me in ASR’s BTOP evaluation study.
As explained in the introduction to its final report, published in September 2014, ASR Analytics summarized the scope of and general methodologies used in its study:
The scope of work includes an assessment of the benefits that BTOP grants are having on broadband availability and adoption, and in achieving social and economic benefits in areas served by the grantees…
ASR developed its conclusions based on a mixed- methods approach that includes comparative case studies of BTOP-funded projects, input-output analysis of the short-term economic impacts of all BTOP budgetary spending, and a matched-pairs analysis of the counties served by infrastructure grants in the evaluation study sample.
The ASR study had lots of ground to cover and, in my view, did an admirable job of using mixed methods to leverage available qualitative and quantitative data to evaluate a large number of projects spanning three major categories: Comprehensive Community Infrastructure (CCI), sometimes referred to as “Middle Mile Fiber” projects, Public Computer Centers (PCCs) and Sustainable Broadband Adoption (SBA) projects. And, importantly, as ASR noted in the introduction to its final report, it was “required to provide NTIA with all data that created a foundation for the [report’s] analysis and conclusions, as well as all data that could be utilized by future researchers.”
In this blog post I’m going to focus on a few elements of ASR’s analysis of the impacts of CCI projects, whose purpose and nature are, in my view, closely tied to the issues surrounding the special access market. This is because most if not all CCI projects involved construction of fiber networks providing high-capacity, high-reliability connectivity to “community anchor institutions” (CAIs), including schools, libraries and government and healthcare facilities, as well as providing non-discriminatory open-access backbone connections to wholesale and last mile service providers.
As I see it, the BTOP CCI projects represent a significant wave of new players entering the special access space, the bulk of whose construction costs (up to 80%) were covered by federal grants, and whose terms of service are required to meet certain nondiscriminatory “open access” requirements. And, conveniently and importantly, thanks to NTIA and ASR, these projects have been the subject of careful study from their inception.
Though there’s plenty we can learn from the ASR study of CCIs, I’m going to focus here on some high-level numbers that the study gathered, estimated and extrapolated.
According to Table 7 on pg. 15 of ASR’s final report, the total amount (including both federal grants and matching funds) budgeted for 109 CCI projects was $3.9 billion. The table also indicates that, at the time the study was done, these projects had connected 21,240 CAIs, at a budgeted cost of $184,141 per CAI. Assuming federal grants paid for 80% of this total cost, the average federal grant amount per CAI would be in the neighborhood of $147,300.
Table 13 on pg. 34 of the report shows the changes in subscription speeds and pricing experienced by the 86 CAI locations providing this information to ASR. The table shows very large increases in speed and, depending on the category of CAI, dramatic 94-96% average reductions in per-Mbps pricing. Table 14 on pg. 36 uses these reported changes in speed and price to extrapolate CAI cost savings from switching to CCI-provided fiber connections. Averaged across all CAI categories, the per-CAI annual savings amounted to $236,151.
So, in a single year, the average CAI saved well more ($236,151) in operating costs than the total capital cost ($184,141) required to connect it to a CCI fiber network.
These direct cost savings to CAIs were only part of the impacts considered by ASR. It also used previously developed models to estimate other economic benefits, as explained on pg. 33 of its final report:
Increased economic output: The largest long-term social or economic impact due to BTOP infrastructure spending is the yearly increase in GDP in the areas served by the new broadband infrastructure. ASR used two studies, Czernich et al. (2011) and LECG Ltd. (2009), to extrapolate the increase in economic output that could be expected in counties receiving BTOP- funded infrastructure. For the base case of a 2.0 percent increase in broadband availability, BTOP infrastructure spending could be expected to yield $5.7 to $21.0 billion in increased output annually using results from Czernich et al. (2011) and LECG Ltd. (2009) as the bases for extrapolation, respectively.
Long-term increased levels of employment: Kolko (2010) and Gillett et al. (2006) provide a basis for estimating the long-term increase in employment due to BTOP-funded infrastructure spending. Based on Kolko’s estimates, the additional broadband infrastructure provided by BTOP could be expected to create more than 22,000 long-term jobs and generate $1.1 billion in additional household income each year. Results from Gillett et al. (2006) suggest at least 6,900 long-term jobs could be created in the year following the construction of BTOP infrastructure, and potentially each year for at least the next four years due to increasing employment growth in areas with new broadband availability. These employment increases would result in a $328 million increase in household income for each year employment increases by the estimated amount in newly served areas.
Value to new subscribers: The Allen Consulting Group (2010) finds the value of broadband Internet access to the average American household is about 3.4 percent of average household income. Using the base case to determine the number of households adopting broadband, this translates into an estimated value of broadband to new subscribers of $2.6 billion per year.
Given all of the above, the CCI component of NTIA’s BTOP program strikes me as a very good investment of public funds in that it: 1) delivers substantial direct and indirect net social value, as suggested by the ASR study and; 2) helps correct the substantial excess-profit market failure suggested by both the CFA analysis and the dramatic cost savings reported by CAIs after connecting to BTOP-funded CCI fiber networks. And given these strong indicators of net social value, I’d suggest that the federal government consider expanding its CCI investment in geographic areas that the FCC’s special access data collection project indicates still face a lack of competitive options and an abundance of excess-profit-extracting prices in the special access market.
I’ll have more to say about this perspective in future posts.
I’ve been thinking a lot lately about the design and management of society’s core infrastructure systems (which I define broadly to include things like healthcare, education, housing and “money”) in an era marked by several important trends (for reasons suggested below, I refer to this as the “digital anthropocene”):
To flesh this out a bit, here are some examples of developments reflective of these trends (some of which I’ve already written about here):
In the following video, President Obama announced several steps his Administration is taking to encourage municipally-owned broadband networks, as well as the rationale for taking them.
A few weeks after the president’s January 14 speech, the FCC announced it would be voting on a similar approach to municipal broadband at its February 26 meeting, where it will also vote on a proposal to classify broadband access as a Title II common carrier. Since community broadband is a topic I hope to write about here in the future, and the Commission’s meeting is only two weeks away, I thought I’d share some initial thoughts on the subject, using the President’s plan and its significance as a focal point.
As always, feedback (especially from those who see this issue differently) is welcome…