Don’t Believe ‘Special Access’ Hype

by on June 24, 2009 · 27 comments

A new coalition, NoChokePoints, has been formed to lobby Congress and the Federal Communications Commission to further regulate the prices that incumbent telephone companies (Regional Bell Operating Companies or Incumbent Local Exchange Carriers) can charge for special access services purchased by businesses and institutions.  Special access circuits are dedicated, private lines.  For example, Sprint purchases special access circuits to connect its cell towers to its backbone.

According to a coalition spokeswoman,

Huge companies like Verizon and AT&T control the broadband lines of almost every business in the United States. The virtually unchallenged, exclusive control of these lines costs businesses and consumers more than $10 billion annually and generates a profit margin of more than 100 percent for the controlling phone companies, according to their own data provided to the FCC. This hidden broadband tax results in enormous losses for consumers and the economy, and this country cannot afford it; especially now.

An analysis prepared by Peter Bluhm with Dr. Robert Loube under contract with the National Association of Regulatory Commissioners (NARUC) disputes this conclusion.
NARUC represents both state utility commissioners who are pro-business as well as state utility commissioners who are hostile toward regulated utilities.  NARUC is not supporting the incumbent network providers on the issue of special access regulation.  According to Bluhm and Loube,

Buyers have criticized the FCC’s current regulatory regime because it has apparently allowed excessive earnings. For their part, the RBOCs contend that the ARMIS figures are virtually meaningless. We agree with the RBOCs ….

Before 2000, special access investment was categorized by what is called “direct assignment.” The purpose was to assign 100% of investment for interstate special access to the interstate jurisdiction and 100% of investment for intrastate special access to the state jurisdiction. In practice, direct assignment required carriers to perform studies on how their networks were used ….

In 2001, the FCC “froze” separations categories and factors for large companies. At that point, large carriers stopped performing direct assignment studies ….

During [the ensuing] period, carriers greatly increased their sales of interstate special access, and all of that revenue was assigned to interstate. As a result, interstate special access revenues increase every year, but not interstate special access costs.  This imbalance has inflated ARMIS special access earnings reports and made them unreliable. (emphasis added.)

Likewise, a paper by Harold Ware, Christian Dippon and William Taylor at NERA Economic Consulting concludes,

accounting profits generated from [ARMIS] data bear no relationship with economic profits and cannot serve any useful purpose in determining whether pricing flexibility has generated excessive rates of return.

In an effort to get to the bottom of this, Bluhm and Loube estimated the current actual cost and found that the carriers are probably earning substantially less than ARMIS indicates.  Instead of earning a 138% return on special access investment, AT&T is more likely earning 30%.  Qwest is probably earning 38%, not 175%.  And Verizon, 15% instead of 62%.

The revised percentages are still more than a regulated utility would be allowed to earn.  However, there are at least two points to consider.

First, absent cost studies there is no way to know how much the network providers are earning.  According to Ware, Dippon and Taylor,

allocations and adjustments can produce wildly different results depending on what factors are used. This is why economists and regulators have long rejected use of cost allocations such as those in the ARMIS data. It is also why [Bluhm and Loube’s] conclusions regarding profits for special access should be summarily rejected.

Incidentally, Ware, Dippon and Taylor predict that the potential benefits of additional special access regulation are not worth the “potentially large costs.”

They point out that if different adjustments are chosen, the return on investment could be even lower.

For another, competitors are entering the market and they are capturing market share.  Bluhm and Loube concede that

Cable television and fixed wireless have low entry and exit costs where their networks are currently established, and each can provide substitutable dedicated services to many customers. Overall, these competitors are still acting on the fringes of special access markets, but they have larger roles in some locations and their market shares appear to be growing. Fixed wireless may hold a large market share in five years, particularly if WiMAX proves reliable and if these carriers can attract sufficient capital to expand. These newer technologies may be poised to become major competitors and are increasingly constraining ILEC behavior, but they have not yet grown beyond fringe competitors in most markets.

Maybe these competitors are still “acting on the fringes” because profit margins afforded by the market aren’t fat enough.

If AT&T, Qwest and Verizon are earning excess profits, cable and fixed wireless competitors will be able to undercut their prices and capture market share. The higher the profits, the faster the entry.

What would happen if Congress or the FCC decided to intervene?  If regulation pushed special access prices lower, that would reduce the revenue investors could expect to earn from new competitive facilities.  If investment won’t be profitable, it won’t be made.

NoChokePoints includes telecommunications providers Sprint, BT (British Telecom) and tw telecom among its members.

These competitors would not be pushing to cap the special access prices charged by incumbent network providers if they wanted to profitably invest in competing facilities.  They would want incumbent providers to charge high prices so they could charge lower prices and still make a profit.

The logical conclusion is that competitors don’t want to invest in new facilities.  They simply want to cut costs.  (Sprint, which has partnered with Clearwire and is exploring a combination with Level 3, is hedging its bets.)

A desire to cut costs rather than assume investment risks is not surprising.

But the coalition claims that additional special access regulation will create jobs.

Policymakers need to consider whether they want to help companies who don’t want to invest save jobs at the expense of their suppliers, or whether it would be better to maintain incentives for investment.  Investment will create sustainable jobs.

Cost cutting will simply lead to more layoffs, here or there.

The message for Congress is: (1) the “controlling phone companies” are not earning margins in excess of 100%, according to any credible observer; (2) determining what the exact margin really is would require cost studies which are expensive, time consuming and would probably lead to litigation and (3) if prices do exceed reasonable costs it will be profitable for competitors to invest in new facilities which will create needed jobs.

For more information, a recent column I wrote about proposals to expand special access regulation can be found here.

  • Brett Glass

    “Special access” is one of the few telecommunications markets which is truly in a state of market failure and does deserve government attention. To see why, let's take a step back and understand what's really going on here.

    The first thing folks need to understand about this issue is that there's nothing “special” about “special access.” It consists of the ordinary wholesale connections, often called the “middle mile,” which connect cell phone towers to the telephone system and ISPs to the Internet backbone.

    The second thing you need to understand is that overcharging for “special access,” if it's allowed to continue, will lead to a cellular duopoly in many parts of the country or maybe even the whole country. Why? Because AT&T and Verizon, the two large telephone monopolies, are also cellular providers. When they do business in each other's territories, each overcharges the other for the “special access” lines which are necessary to hook their towers up to the phone system. But since they do this about equally to one another, it's a wash. However, cellular providers which are not also ILECs (telephone monopolies) do not have anyplace to overcharge back. They have to pay the exorbitant prices everywhere. So, the two biggest providers, which are also ILECs, can very easily put the others out of business over time and achieve a nice, cozy duopoly. That's why Sprint and T-Mobile are so much in favor of doing something about the price gouging: their long term survival depends upon it.

    The third observation which is interesting is that the remaining ILEC, Qwest, doesn't offer cell phone service. This is intentional. Their idea is to overcharge everyone for “special access” without having to pay any of that money back out! This is how Qwest hopes to prosper without getting into the wireless business in competition with the larger ILECs.

    Finally, it's important to understand how all of this affects ISPs, including cable companies. ISPs, in nearly all locations, have to buy “special access” lines to connect themselves to the Internet backbone. But the ILECs charge incredibly high prices for it. In fact, to get Qwest to carry data 45 miles in my region costs about twice as much as an Internet backbone provider charges to take it to the rest of the world! This drives up the cost of bandwidth outside major cities. Our rural ISP's net cost of bandwidth is about $100 per Mbps month, and some ISPs we know are paying $300 to $400 per Mbps per month. Obviously, at these prices, we can't allow the use of bandwidth hogging applications without caps, metering, or simply prohibiting some of the worst applications (e.g. BitTorrent) altogether.

    For all of these reasons, it's important to do something about this issue. Even if you just use a cell phone and not the Internet, you have good reason to want the government to fix this failed market.

  • mwendy

    Probably the real tension is the fact that NCP members’ business models place a large bet on leasing special access facilities instead of building them. Combined with the popularity of their offerings, their services have become more competitive between each other, eroding their profit margins. The law allows that they could build out their own facilities, but they chose / choose not to. So, they need to look for other inputs to lower in order to maintain more profitability. Special access – for now – is that target.

    It’s actually a success story. But, not the way they see it. Clearly, there’s tons of innovation at the edge of the network, with the rollout of more such services emerging daily. Many of these services could not have occurred without the first mover / initial innovation of the special access line itself. Yes, a lot of those lines are provided by incumbents. We surmise that a lot of special access is also provided by competitors (but we don’t have all that data because they’re not required to provide it). These and other methods provided within the ’96 Act have fostered an environment where competitive entry can occur. Rightfully, it does not guarantee success of any one model of entry.

    Were only incumbents obligated to build out facilities, and competitors free to free-ride between technological bets? Of course not. The framers of the ’96 Act provided many paths to competition, whatever methods it may take. Perversely, though, NPC asks to the FCC suspend this openness (and the laws of economics), assigning a role to incumbents of “risk-taker of only resort”. They seek to penalize those who provide an input they so highly desire, but remain unwilling to build out themselves, let alone pay reasonable fees to employ.

    American broadband users need providers to build out facilities-based competition because our communications run on real networks, via real infrastructure. It cannot all be done through resale and leasing. You need the actual pipes. And, someone has to be rewarded to build them out and run them. Though NPC “pooh-poohs” this notion – rate re-regulation greatly diminishes the incentive for new and exciting initial innovation to make it to the marketplace. Should this occur, less innovation at the edge makes it to consumers, too.

  • Brett Glass

    Building out redundant “middle mile” facilities is not only economically inefficient; it's financial suicide. Remember, the financial graveyard is littered with the corpses of companies that thought they could make lots of money by running fiber where others had already done so.

    One of the reasons for this is that it's the first strand of fiber in the ground that costs all the money; additional ones are virtually free. This means that any company which runs a redundant fiber route will be subject to targeted predatory pricing by the ILECs — which actually have plenty of fiber available and are artificially inflating the price of access. They will thus incur huge costs on the first strand (which they need for themselves) but be unable to make them up by selling access to additional strands.

    In short, to require every provider to own all of its own fiber is to perpetuate market failure and guarantee a monopoly or duopoly. The essential facilities doctrine applies as much to fiber as it did to railroads in an earlier age.

  • mwendy

    Brett, there's not a piece of the ILEC's / incumbents' networks that doesn't succumb to your “middle mile, it's not right to require redundant facilities from others” argument. It might as well all see confiscation by the FCC.

    But you do hit on a lager truth – it is “financial suicide” to base your business model (i.e., essentially resale) on the hopes that regulators will expropriate special access from an incumbent. That's a fool's errand (sadly, there's tons of redundancy there).

    How special access gets regulated, as I understand it, is a market-by-market determination. Where there's competition, pricing flexibility beyond price caps gets employed. Thus, a blanket rule is infeasble.

    Fiber ain't the only way to make it to a POP or CO – but that's a whole different issue.

    In a larger sense, many of these Soros-funded groups, if they were successful, would diminish investment and innovation from the very entities that are best situtate to roll out initial innvoation – the raw stuff that enables all the innovation at the edges.

    Good code and marketing expertise does not a network make. Real lines – landline, satellite, wireless, wimax, BPL, cable, etc. – connecting other networks take real risk to grow. New and better ways of making these connections will occur. Yet, that stands far less of a chance of happening if market leaders get penalized for taking that risk due to the regulatory neutering / Soros-ing of that innovation.

    That noted, however,

  • Brett Glass

    Let's put aside, for the purposes of this discussion, the ad hominem digs at George Soros and talk simple economics. (I don't agree with him on many issues, and am under attack myself by several of the groups which he funds simply because I am an ISP; however, attacking him adds nothing to the discussion.)

    Many of the entities which are correctly arguing for correction of the failure of the “special access” market are not regulators or lobbyists but real, for-profit, productive businesses — including Sprint and T-Mobile — which have extensive investments in the “real lines” you mention above. My company also does; we're a wireless last mile provider. In fact, I work 7 days bloodying my knuckles building out our infrastructure.

    However, we're in real danger of being forced out of business by the anticompetitive tactics of the ILECs, which are trying to destroy competition by preventing us from obtaining wholesale bandwidth — the product which our network distributes — at a reasonable cost.

    If one were to follow your line of reasoning above, there could be no providers which specialized in “last mile” access — or, in fact, which specialized in any one portion of broadband delivery. To play at all, a company would have to be 100% vertically integrated. It would have to own everything from soup to nuts: backbones, middle mile fiber, and the last mile. This would destroy any opportunity for market entry and would kill any provider which did not already own all of these things, since it would not be possible to raise capital to build them.

    It's also worth noting that the ILECs funded the building of their fiber with monopoly rents and government subsidies (e.g. USF and the E-rate) which are not available to us. The market merits correction for this reason as well.

    In short, what you recommend would be a recipe for total market failure in broadband provision — from the backbone to the last mile.

  • Brett Glass

    Let's put aside, for the purposes of this discussion, the ad hominem digs at George Soros and talk simple economics. (I don't agree with him on many issues, and am under attack myself by several of the groups which he funds simply because I am an ISP; however, attacking him adds nothing to the discussion.)

    Many of the entities which are correctly arguing for correction of the failure of the “special access” market are not regulators or lobbyists but real, for-profit, productive businesses — including Sprint and T-Mobile — which have extensive investments in the “real lines” you mention above. My company also does; we're a wireless last mile provider. In fact, I work 7 days bloodying my knuckles building out our infrastructure.

    However, we're in real danger of being forced out of business by the anticompetitive tactics of the ILECs, which are trying to destroy competition by preventing us from obtaining wholesale bandwidth — the product which our network distributes — at a reasonable cost.

    If one were to follow your line of reasoning above, there could be no providers which specialized in “last mile” access — or, in fact, which specialized in any one portion of broadband delivery. To play at all, a company would have to be 100% vertically integrated. It would have to own everything from soup to nuts: backbones, middle mile fiber, and the last mile. This would destroy any opportunity for market entry and would kill any provider which did not already own all of these things, since it would not be possible to raise capital to build them.

    It's also worth noting that the ILECs funded the building of their fiber with monopoly rents and government subsidies (e.g. USF and the E-rate) which are not available to us. The market merits correction for this reason as well.

    In short, what you recommend would be a recipe for total market failure in broadband provision — from the backbone to the last mile.

  • Brett Glass

    [Moderator, please delete the redundant copy of my posting just above.]

    P.S. — By the way, the fact that my company, and others, do indeed build out infrastructure puts the lie to the notion that “there's not a piece of the ILEC's / incumbents' networks that doesn't succumb to your “middle mile, it's not right to require redundant facilities from others” argument.” My company, and many others, are doing a very good job of creating useful, productive infrastructure. However, if anticompetitive practices are used to choke off the inputs to our business (and all industries have inputs), there can be no prospect of a healthy, competitive market.

  • mwendy

    Brett, you're a piece of the puzzle, being (somewhat, mostly?) facilities-based at the “last mile.” But, I think what you're saying is “to play at all” the investment which you've made must be granted a “network effect”, in a regulatory sense. I do not agree with that.

    Y'all made a choice. You build out the last mile where there're ostensible ILEC / cable / technical bottlenecks, in the hopes that…???

    “Failure” is as narrow as one wants to paint it – that is, when one seeks to gain access to an input that they didn't tell shareholders might be beyond their control. Or, were unable to get funding to go the distance.

    The charges made by the ILECs are presumptively reasonable, having gone through nearly 20 years of wrangling to get there. But, if new facts in given markets show that competition doesn't exist – that Sections 201, 204, 208, 251 and 271 (for RBOCs) of the '96 Act aren't working – by all means make those specific cases. I presume you're doing that. But, that's not what I gather NPC's doing. They say it's all broken, a failure. So, now they're making their appeal to a higher law…through PR.

    On the USF, the ILECs have seen regulation (something which I presume you see little of since you're a CLEC) for nearly 100 years. They're the last resort. You cherry pick (sorry for the ad hominem here). Cherry picking means you had choice in the first place. You can decide which heartburn you want to undertake, which markets you want to enter.

    While I appreciate your going the extra “last mile” with some facilities-based competition, the network effect you seek was not a guarantee of the '96 Act. Yet, if y'all make it that, less innovation will result because fewer will be called to the table through economics / human nature to develop the “bypass” which you crave but do not have means to effect technologically or monetarily.

  • Brett Glass

    Sorry, but you're incorrect on several points here. Firstly, I'm not a CLEC. I'm an ISP. Secondly, if one were to follow your argument, no one should ever get into any business that required electric power unless one had the money to string up a nationwide power grid. Thirdly, I'm not relying upon any “network effect.” I'm simply relying upon being able to get the wholesale inputs I need for my business, without being harmed by clearly anticompetitive tactics in a failed market. I've been able to get them up to this point, but the ILECs are now seeking to squeeze out all competition. If you're truly an advocate of free markets, you should recognize attempts to destroy them; this is such a case.

  • mwendy

    Brett, I'm not getting you. You're an ISP, but also a last mile provider? You're buying / supplanting UNEs for your service – what you do with them at that point is immaterial. You're an unregulated CLEC-ish entity in my book.

    That noted, your vertical argument misses the point. You provide an input yourself to the end-user's benefit. I think you are confusing that benefit with your own. You have to cobble together all the other inputs in order to provide end-user benefit, which brings about the ensuing innovation at the edge from that end-user (like the user of electricity in your example). They don't need to see anything but your output (ISP / CLEC services).

    Clearly anti-competitive tactics in a failed market? – sounds like a mantra from NPC. What specific market are you talking about? What are those specific tactics? Do you know how much it costs the ILEC to provide you with special access? How do yo know it's not “wholesale”. What are the available alternatives? What other infrastructure allows bypass? Who competes in that same marketplace? Who competes with you? What do determine to be the relevant market for the end-user?

    Or, is it – the rate is simply more than you want to pay? And, that's the extent of the anti-competitive behavior.

  • Brett Glass

    Yes, I will agree that you are not “getting me.” First of all, I do not buy unbundled network elements (UNEs), nor am I a CLEC. I am a wireless ISP — a true last mile provider and an honest to goodness American small business. I bring choice to users who are served by the telephone and cable monopolies and bring broadband to areas which these companies — all large, out-of-state corporations who care nothing for our community except as a cash cow from which to extract monopoly rents — do not deign to serve.

    You will also note that I am not a member of the “no choke points” coalition (which I assume is what you mean by “NCP” above), because its organizers — the lobying groups Public Knowledge and Media Access Project — are lobbying for excessive regulation of all ISPs, which would actually kill competition.

    I do not wish to be granted any sort of boon by the government whatsoever, nor do I want to see unnecessary regulation. I ask only that it prohibit anticompetitive practices, as it should in all industries, and address the problem of failed markets for essential services.

    As I mention in my blog posting at http://bennett.com/blog/2009/06/whats-this-i-he…, the market for “special access” is indeed broken. And the ILECs are leveraging this monopoly to create monopolies in other industries. (If we do nothing about this issue, expect to see only two cellular carriers in most if not all of the United States: AT&T and Verizon.) As most readers here will know, such monopolization is illegal and well as destructive to free markets. Just as with the railroads during the Gilded Age, bypass is financially infeasible, so the markets cannot self-correct. It is therefore entirely appropriate for government to step in in this specific case.

  • mwendy

    Your issue as I understand it is with Level 3 – are they an ILEC? Isn't Qwest (or a local coop) the ILEC there in Laramie?

    Two – you provide services a lot like a local exchange – I would guess that VOIP is one such offering (or use). That says CLEC to me.

    Third, you chose to serve this market. You cherry picked it, and that obviously has costs. The '96 Act can only go so far, and hence your claim that the market is broken to mitigate. it did not guarantee success for you. Infeasibility, well, you knew where it'd be. Now you're asking for the government to help out.

    I do not belittle your task or what you've done. It's good stuff. yet, I do wonder when I see in your Stanford presentation and elsehwhere little more specific than “it's a broken market.” I mean, you've mentioned it a half-dozen times, yet offer little more than the line.

  • Brett Glass

    It's clear that you need to brush up on the facts before commenting. No, Level3 is not an ILEC. Qwest is, of course. And, no, Internet access is not at all like POTS. We are, most emphatically, not a local exchange carrier.

    Nor did we “cherry pick” our market. We serve it because it's where we live and we want to serve the community. It's not a “cherry” to be picked in any sense of the word.

    Nor are we relying on the provisions of the Telecommunications Act of 1996, which has been gutted by the courts and neglected by Congress. (It appears, again, that you are confusing us with a CLEC.)

    Again, you appear to have such severe missconceptions about who we are and what we do that I wonder how you could be writing about telecomm.

  • mwendy

    You talk about ILECs harming you yet your testimony at Stanford was about Level 3, which is not an ILEC.

    CLEC is any provider of by-pass that compete with e LEC. Which you say you do.

    I will not even address your cherry-picking.

    Again, what are your specific concerns with the ILEC (not Level 3)? Specifics instead of just “it's broken.”

  • http://twitter.com/iansltx Ian L

    It's the ILECs that do the cherry picking.

    Some locations (my hometown and the place I'm posting this form) simply don't have DSL from the ILEC. Yet they still charge ridiculous rates on their middle mile services. I'm sure they'd actually get MORE business if they charged a decent amount for 'em, but anyway…

    Brett is NOT a CLEC. That's a regulatory term, and you don't know what you're talking about. Am I a CLEC if I takea Linksys router and make an open WiFi network at my coffee ouse, which you can run VoIP over? How about if I collected money for that hotspot? How about if I had a mesh network to cover a neighborhood and bought VoIP minutes wholesale, then distributed them among the community? I wouldn't be a CLEC.

    There's a local WISP where I live. They're not a CLEC. VoIP can run over their network, but if they did VoIP they'd have to buy numbers from Verizon, at a cost of a few bucks per number plus $600 for a PRI.

    Let's face it though: ILECs don't know anything about being a WISP. Cellular data with 5GB caps don't count. Especially when it's not available in places where they don't have DSL. The bottom line is, if you don't have cable or DSL available at your address, who ya gonna call? Satellite? Or a local WISP with latency comparable to cable or DSL, and speeds better than sat?

    I'll bet you're posting from a cable or DSL connection right now. Provided either by an MSO or an ILEC. Both of which tend to be anticompetitive in the very markets that are the most underserved. The ILECs, and to some extent the MSOs, cherry pick what places they want to serve, then leave everyone else out in the cold. Yet those same providers keep dedicated link pricing (aka special access) at ridiculous levels so it's difficult for ISPs to enter into the business, especially since people are using more and more bandwidth and prices for T1s, T3s, etc. have dropped relatively little.

    Would you prefer satellite internet to high-speed wireless, which would compete enough to drive down internet prices in the community, even in areas served with DSL or cable? Or would you rather pay $50 per month for a metered 512k high-latency connection because the ILEC passed you by, because you felt that y=the ILEC was justified in keping alternative access in underserved areas out of sight?

  • Brett Glass

    From the above, I can only conclude that you're working for one or more ILECs and are a paid mouthpiece for them.

    My testimony at Stanford, which can be found at http://www.brettglass.com/FCC/remarks.html, was about “network neutrality” regulation, not about the issue of “special access.”

    During that testimony, I just happened to mention, in passing, that Level3 owns three fiber routes through our community and refuses to provide us with service from any of them — leaving us at the mercy of the ILEC for transport. The ILEC then gouges us for transport. We have spoken with Level3 many times, and it appears that Level3 is colluding with the ILECs, which are very large customers.

    My specific concerns with the ILEC, as I have mentioned several times above, is their anticompetitive price gouging on “special access.” This isn't just “kvetching;” it's vital to the future of telecommunications in the US. For more — and quite a lot of detail — readers should see my blog posting at

    http://bennett.com/blog/2009/06/whats-this-i-he

  • Anonymous

    I will be out of the office until from April 10 – 17, so if you need anything immediately, please call 202-841-7209. Thanks!

    CONFIDENTIALITY AND PROPRIETARY INFORMATION NOTICE: This email including attachments, is covered by the Electronic Communications Privacy Act (18 U.S.C. 2510-2521) and contains confidential information belonging to the sender which may be legally privileged. Nothing contained in this message or in any attachment shall constitute an Electronic Signature or be given legal effect under 44 U.S.C. 3504 Sec. 1707. The information is intended only for the use of the individual or entity to which it is addressed. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or the taking of any action in reliance of the contents of this information is strictly prohibited. If you have received this electronic transmission in error, please immediately notify us by phone or arrange for the return of the transmitted information to us.

  • Brett Glass

    Until April 10? Today's July 7th. That's a long vacation. ;-)

  • mwendy

    I will be out of the office until from April 10 – 17, so if you need anything immediately, please call 202-841-7209. Thanks!

    ________________________________
    CONFIDENTIALITY AND PROPRIETARY INFORMATION NOTICE: This email including attachments, is covered by the Electronic Communications Privacy Act (18 U.S.C. 2510-2521) and contains confidential information belonging to the sender which may be legally privileged. Nothing contained in this message or in any attachment shall constitute an Electronic Signature or be given legal effect under 44 U.S.C. 3504 Sec. 1707. The information is intended only for the use of the individual or entity to which it is addressed. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or the taking of any action in reliance of the contents of this information is strictly prohibited. If you have received this electronic transmission in error, please immediately notify us by phone or arrange for the return of the transmitted information to us.

  • Brett Glass

    Until April 10? Today's July 7th. That's a long vacation. ;-)

  • mwendy

    I will be out of the office until from April 10 – 17, so if you need anything immediately, please call 202-841-7209. Thanks!

    ________________________________
    CONFIDENTIALITY AND PROPRIETARY INFORMATION NOTICE: This email including attachments, is covered by the Electronic Communications Privacy Act (18 U.S.C. 2510-2521) and contains confidential information belonging to the sender which may be legally privileged. Nothing contained in this message or in any attachment shall constitute an Electronic Signature or be given legal effect under 44 U.S.C. 3504 Sec. 1707. The information is intended only for the use of the individual or entity to which it is addressed. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or the taking of any action in reliance of the contents of this information is strictly prohibited. If you have received this electronic transmission in error, please immediately notify us by phone or arrange for the return of the transmitted information to us.

  • Brett Glass

    Until April 10? Today's July 7th. That's a long vacation. ;-)

  • mwendy

    I will be out of the office until from April 10 – 17, so if you need anything immediately, please call 202-841-7209. Thanks!

    ________________________________
    CONFIDENTIALITY AND PROPRIETARY INFORMATION NOTICE: This email including attachments, is covered by the Electronic Communications Privacy Act (18 U.S.C. 2510-2521) and contains confidential information belonging to the sender which may be legally privileged. Nothing contained in this message or in any attachment shall constitute an Electronic Signature or be given legal effect under 44 U.S.C. 3504 Sec. 1707. The information is intended only for the use of the individual or entity to which it is addressed. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or the taking of any action in reliance of the contents of this information is strictly prohibited. If you have received this electronic transmission in error, please immediately notify us by phone or arrange for the return of the transmitted information to us.

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