Read Part II here

In February, Congress passed the Obama Administration’s “(Five Year) National Broadband Plan,” part of the so-called “Stimulus.” (As economist Russ Roberts put it, government “stimulus” is “like taking a bucket of water from the deep end of a pool and dumping it into the shallow end.”) The Plan transfers $7.2 billion from taxpayers to broadband providers in subsides to promote broadband build-out. More than 10,000 comments have been filed on the plan. Once you get past the constitutional nicety of whether Congress has the power to subsidize “internal improvements” like broadband (it doesn’t), you might wonder just how well your money will be spent by all these techno-supplicants for the latest craze in corporate welfare.

The good news is that these comments are available online. Hurray for transparency! The bad news is that… they’re available online—specifically on the FCC’s Electronic Comments Filing System (ECFS). Anyone who’s used the web more recently than 1998 will cringe the first time they try to use ECFS to find anything, as Jerry has noted. Apart from the cumbersome, highly unintuitive interface, the problem is that there’s no way to search the text of comments ! You can only search pre-defined fields like like “law firm,” and if you don’t enter a value in precisely the right way, you get nada.

Bill Cline, the Chief of the Reference Information Center for the FCC’s Consumer & Governmental Affairs Bureau tries hard to put the best face on this farce of e-government, explaining:

A docket number is key to using ECFS, and this link takes you to the ECFS retrieval form with the docket number for the National Broadband Plan, 09-51, already filled in.  Just hit “Retrieve Document List” to get a list of all filings.  Yes, there are lots of them, and you need to click on each individual filing to read it.  But there are many ways you can focus your search, which include:

• Entering the name of a specific individual whose comments you want to see in Field 4 (Filed on Behalf of)
• Narrowing your search to people in your community by using the “City,” “State,” or “Zip Code” fields
• Entering “FCC” in Field 5 – (Law Firm) – to see FCC filings.
• Clicking on the box in field 15 (Eliminate Brief Text Comments) to narrow the search considerably by retrieving only longer comments
• Finding comments for a specific public notice by using a date range on either side of the comment due dates

Keep in mind that this the Federal Communications Commission we’re talking about here.  Yet this antiquated system hasn’t been updated in nearly six years! You might think the problem was just funding: after all, someone would have to pay for a new database system, right?  Yes, but we don’t need a new system: All the FCC has to do is set its robots.txt file to stop blocking search crawlers, so that FCC comments would be included in Google search results, as Jerry has noted.

The real absurdity here is that we naively expect these same regulatory agencies—that can’t even make their own data available through free search engines or stream their own meetings properly—to keep pace with the rapid pace of innovation on the Internet. If only the comedic geniuses at Saturday Night Live had chosen to pick on bureaucrats instead of lawyers, we’d have “Unfrozen Caveman Regulator” instead of  “Unfrozen Caveman Lawyer.” Maybe that would have made it clear to Americans how silly it is to give the least technologically competent among us control over technology, innovation and creativity—or, even better, that no one central authority is smart enough to manage it, even one led by a guy as seemingly Twitterific as Barack Obama.

Obama’s picked some good people to pull government into the Web 2.0 era, but they’ll always be fighting against the tide of institutional inertia inherent in bureaucracy. In short, we may well see a significant upgrade in e-government in the next few years, but it won’t change the basic fact that government just can’t keep pace with technological change. One need not be a libertarian to accept that this basic fact makes the Internet “different.” Thus can even a non-libertarian be a cyber-libertarian of the Internet Exceptionalist variety.

I’ve got a new essay up over at the City Journal about John Nichols and Robert McChesney’s proposal to have the government heavily subsidize failing media enterprises to “save journalism.” It follows below:

“Socializing Media in Order to Save It“ by Adam D. Thierer

City Journal March 27, 2009

With proposals to nationalize or heavily subsidize various segments of our economy more in vogue than ever, it was probably only a matter of time before someone suggested that America’s media marketplace should be brought into the government fold. John Nichols of The Nation and the prolific neo-Marxist media theorist Robert W. McChesney have now provided the road map for media’s march to serfdom. The cost to the American taxpayer would be at least $60 billion, but the cost for the First Amendment and our democracy would be incalculable.

Nichols and McChesney have coauthored several books and essays about media policy that view the world through the prism of class struggle, “manufactured consent” (á la Noam Chomsky), and the rest of the typical Marxoid tripe about history and economics. In their view, private, for-profit media cannot be trusted. As they stated in their 2003 call to arms, Our Media, Not Theirs: The Democratic Struggle Against Corporate Media, media-reform efforts must begin with “the need to promote an understanding of the urgency to assert public control over the media.” “Our claim,” they continue, “is simply that the media system produces vastly less of quality than it would if corporate and commercial pressures were lessened.”

In a new Nation essay, “The Death and Life of Great American Newspapers,” the authors bring their earlier work to its logical conclusion. Saving journalism, they argue, essentially requires that media become an appendage of the state. Journalism, they claim, is a “public good,” which—like education and defense—requires constant government oversight and support: “A moment has arrived at which we must recognize the need to invest tax dollars to create and maintain news gathering, reporting and writing with the purpose of informing all our citizens.” They propose that government devote $60 billion to “subscription subsidies, postal reforms, youth media and investment in public broadcasting.” Think of it as a “free press ‘infrastructure project,’” they say. “It would keep the press system alive. And it has the added benefit of providing an economic stimulus.” (Isn’t it amazing how everything stimulates the economy these days?)

Perhaps most audaciously, they argue that policymakers must respond to the crisis in journalism “with the same urgency with which they would approach the threat of terrorism, pandemic, financial collapse or climate change.” And they proclaim that their subsidy proposals are entirely consistent with what the nation’s Founders would have wanted:

We have to open the door to enlightened public policies and subsidies. . . . We need an organized citizenry demanding the institutions that make self-government possible. Only then can we, like our founders, build a free press. The technologies and the economic challenges are, of course, more complex than in the 1790s, but the answer is the same: the democratic state, the government, must create the conditions for sustaining the journalism that can provide the people with the information they need to be their own governors.

The Founders cared about a free press, of course, but they didn’t call for massive public subsidies to achieve it. They did put in place one rather important provision—the First Amendment—suggesting what they believed constituted a truly free press: “Congress shall make no law . . . abridging the freedom of speech, or of the press.”

Nichols and McChesney seem utterly naive, however, about the dangers to the First Amendment of putting government in control of media’s purse strings. “We must have a system that prohibits state censorship and that minimizes commercial control over journalistic values and pursuits,” they maintain. Well, good luck with that. If eight decades of Federal Communications Commission meddling in media markets have taught us anything, it’s that if you give bureaucrats the power to regulate the size and the shape of a soapbox, they will inevitably use their authority to regulate the speech delivered on that soapbox—indecency regulation, educational-television mandates, public-access rules, and the Fairness Doctrine are only a few examples. If the FCC received grant-making authority to dole out subsidies to media operators as Nichols and McChesney desire, it’s hard to imagine how journalists won’t be expected to surrender something in exchange. (Consider in this light the bill that Senator Benjamin L. Cardin (D-MD) introduced this week that would allow newspapers to become nonprofit organizations in an effort to help them stay afloat, but would also disallow political endorsements on their editorial pages.)

Nichols and McChesney in fact do envision strings being attached to public financing. They call, for example, for an annual tax credit for the first $200 each American spends on daily newspapers. To be eligible for this indirect subsidy, though, the reader must purchase media that meet criteria set by . . . Nichols and McChesney: “Newspapers would have to publish at least five times per week and maintain a substantial ‘news hole,’ say at least twenty-four broad pages each day, with less than 50 percent advertising.” Missing, moreover, is any mention of who defines what constitutes “news.” It wouldn’t take long for such a process to become a politicized nightmare.

Nichols and McChesney would also require that recipients of this “stimulus subsidy” make at least 90 percent of their content immediately available, free of charge, online. That’s an underhanded way of converting journalism into a giant, government-sponsored commons. (Incidentally, I can’t help but notice how many of Nichols’s essays are locked down on the Nation website, available only to subscribers.)

Nichols’s and McChesney’s argument shouldn’t simply be dismissed as radical, pie-in-the-sky theorizing. The authors have successfully spearheaded an increasingly influential media-reform movement through Free Press, the activist group they cofounded in 2002. The organization’s boisterous band of reformistas work tirelessly to mobilize troops whenever the slightest whiff of media liberalization is in the air. Nichols’s and McChesney’s new article gives us a taste of what we might expect their reform allies in Congress to propose next.

Nichols and McChesney are right about one thing: America’s media operators are struggling in the face of unprecedented competition and unexpected technological change. But the medicine they prescribe is far worse than the disease—for both the profession of journalism and for democracy itself.

Our readers may be interested in this excellent WSJ article, Too Risky for Venture Capitalists: Why proposals for a government bailout were roundly rejected.  We should all take heart in the the fact that the venture capital community itself resoundingly opposed the notion of accepting a massive infusion of taxpayer money, especially Tom Friedman’s suggestion:

“You want to spend $20 billion of taxpayer money creating jobs?” Mr. Friedman wrote. “Fine. Call up the top 20 venture capital firms in America” and invest the money with them.

But I see three more reasons why those interested in technology policy should pay attention to this encouraging episode.

First, the groundswell of opposition seems to have been driven largely by the Internet, both as a vehicle for disseminating the bailout proposals and for voicing opposition to them:

Venture capitalists certainly agree that innovators and start-up companies, not bailed-out GMs or Chryslers, will create the new jobs. They rightly brag that almost 20% of U.S. gross domestic product is generated by companies built by venture capital, such as Intel, Apple and Google. Still, they almost universally panned the notion of taxpayer support. Their real-time rejection is an excellent example of how social media — here, the venture community dissecting a proposal online — can now quickly take down bad ideas.

Second, it should almost go without saying that venture capital is the fountainhead of innovation, especially the disruptive innovation that is constantly pushing the envelope of technology policy.  A healthy VC sector is the bedrock of a dynamic, free and innovative economy.  The VCs realize that this requires, more than anything else, avoiding the market distortions caused by government funding:

“The top venture firms don’t want, don’t need and are never going to take government money. The same is true of the top entrepreneurs,” Fred Wilson of New York’s Union Square Ventures wrote on his blog. “The worst firms, on the other hand, will gladly accept government money,” which would go to investors who can’t raise funds privately and to entrepreneurs whose ideas shouldn’t be funded. “It’s a problem of adverse selection….” The idea of direct government funding is also anathema because it would undermine market discipline. Pension funds, endowments and other institutional investors keep a close eye on how their invested money is doing. Venture firms can raise new funds only if their previous performance was good. Several venture capitalists pointed out the irony that government-funded venture capital could mean trading a credit bubble for another technology bubble. Artificially inflating the venture coffers through a government fund could risk repeating the debacle of 1999-2000, when too much money chased too few good ideas, resulting in the sharp deflation of the Internet bubble. 

Third, the VC community’s response should serve as a lesson for other industries, but particularly high-tech industries, about how the government subsidies they find attractive today in a time of intense pressure on their bottom lines could ultimately harm them.  Instead of jumping on bailout bandwagon, perhaps these industries ought to focus their lobbying efforts on some of the eminently sensible suggestions coming from the VC community, such as the following:

If policy makers want to help entrepreneurs and their investors, there’s no mystery about what’s needed. Immigration needs to be reopened. Venture capital is still available, but the U.S. is now a laggard in the other half of the equation, which is making sure the entrepreneur’s sweat, energy and risk-taking can ultimately pay off. Sarbanes-Oxley helped kill the market for public offerings, which had been a lucrative step for successful start-ups. Income taxes are going up, not down. And the U.S. capital gains tax rate of 15% contrasts with the 0% rate in Hong Kong, Singapore and even Germany, where there’s an understanding that these investments are made with income that’s already been taxed once.

I’ve warned about the dangers of subsidies to the high-tech industry, but I do recognize that the unintended consequences of  subsidizing technological innovation may far outstrip those of subsidizing technological infrastructure, which is what the Obama administration seems to be focused on.  Indeed, if one is going to spend taxpayer money on any subsidies in the name of “stimulus,” it’s difficult to think of a better way to spend that money than on promoting broadband deployment and adoption (however much of a myth it is that we are lagging behind the rest of the world in these areas).  

Still, no matter how worthy the objective, all subsidies distort markets. Few do as much damage as those showered on industries particularly based on risk—e.g., venture capital and financial markets.  But whatever these distortions, the Golden Rule still applies: he who has the gold, makes the rules!  With government subsidies, come government controls.

Yesterday I wrote about some of the questions left open at the launch of Recovery.gov. Today some of these questions are answered in a memo issued by OMB to all agency heads, giving guidance on implementing the Recover Act (PDF). Among other things, the memo lays out their obligations regarding accountability and transparency.

First, I asked yesterday whether the Recovery.gov site being run out of the White House is in fact the Recovery Accountability and Transparency Board website mandated by the Act. The answer seems to be that it is. Everything in today’s OMB memo points to Recovery.gov being treated as the one and only site to comply with the Act’s requirements. I’m not sure this poses a problem for transparency, but we need to be clear that Recovery.gov is not in the Board’s control per se as the Act seems to mandate.

More importantly, however, I asked yesterday how deep reporting would go, and whether reports from stimulus money grantees would be standardized and centrally housed. I wrote:

The problem is that a federal grant could be $10 million to Miami from DoT for roads, and that’s it. There is no requirement that the city then publish its contractors and subcontractors on the Board site. This is a big gap; if the only that must be disclosed on the Board site is the contract or grant award, then the trail will run cold very quickly.

Well, today the OMB helpfully answers me directly:

Reporting requirements only apply to the prime non-Federal recipients of Federal funding, and the subawards (i.e., subgrants, subcontracts, etc.) made by these prime recipients. They do not require each subsequent subrecipient to also report. For instance, a grant could be given from the Federal government to State A, which then gives a subgrant to City B (within State A), which hires a contractor to construct a bridge, which then hires a subcontractor to supply the concrete. In this case, State A is the prime recipient, and would be required to report the subgrant to City B. However, City B does not have any specific reporting obligations, nor does the contractor or subcontractor for the purposes of reporting for the Recovery.gov website. All recipients of Federal funds must continue to comply with existing agency and program reporting requirements.

Like I said yesterday, this gap is a real problem. If one of the things we mean by “accountability” is allowing citizens to help fend of waste, fraud, and abuse, then we must know exactly where the money is going and for what. We need to know more than the fact that New Jersey made a sub-grant to Newark for neighborhood improvement. We need to know whether Newark paid Barone Sanitation and how much.

The upside is that the Recovery Act nevertheless requires grant recipients to report to their sponsoring agency “Detailed information on any subcontracts or subgrants awarded by the recipient[.]” I certainly hope that those reports will be thorough, and that the agencies will publish them in an easy-to-use format. Though I may be reading to much into it, it seems OMB is thinking along the same lines, stating in the memo, “OMB is actively pursuing options for collecting some of this information centrally, focusing first on [subgrant and subcontract information] in the standard formats currently used by Federal agencies to report to USASpending.gov.”

In the not so good news column, detailed project reporting by grantees may not be standardized or centrally housed at Recovery.gov, but scattered in dozens of agency sites in whatever format the grantees submit. Quoth the memo: “OMB is also actively considering how to centralize the collection and reporting of [detailed reporting on projects], though the current preference is that, to the extent possible, this data should be collected and reported through existing program level systems.”

The bottom line is we have no idea right now what Recovery.gov will ultimately look like, and how deeply the promised transparency will go. This reflects the rushed nature of the stimulus plan, as well as the inadequacy of existing federal IT systems. Unfortunately, this means that third parties like Stimulus Watch don’t know what sorts of tools they will be able to build to help citizens hold their government accountable, as the president says he wants them to do.

Sunlight Foundation president Ellen Miller blogged yesterday that “For the site to be successful it has to get the fundamentals right — transparency for the data it will house.” I think she’s absolutely right, but in addition to that we have to make sure that the data housed on Recovery.gov will be of value. Transparency is only a means to an end, and that end is accountability. By this standard, transparency about press releases, presidential YouTube videos, and estimates of how many jobs the recovery plan is creating, is no transparency at all.

The much anticipated site Recovery.gov has just been launched. It has been advertised by the administration as the place where stimulus spending will be completely disclosed to the public. As President Obama says in an introductory video on the home page, “once the money starts to go out to build new roads, modernize schools, and create new jobs, you’ll be able to see how, when and where it is spent” on the web site.

Reading the transparency and accountability portion of the stimulus bill today, however, I’m left with a few questions:

1. The House bill called for the creation of a site to be called Recovery.gov, but that was stripped out from the final legislation. Instead, the Act calls for the independent Recovery Accountability and Transparency Board to create a website to house stimulus-related disclosures. Is the newly launched Recovery.gov that website? If so, is it indeed under the control of the independent Board? Right now the site’s content is certainly not independent of the president. If Recovery.gov is not the same thing as the legislatively created Board website, then won’t the launch of Recovery.gov serve to confuse citizens?
2. I don’t see any mandate in the legislation for deep reporting of how stimulus funding is spent. The Act requires fund recipients to report on a quarterly basis to the agencies from which they received funds (HUD, DoT, DoE, etc.) how they have spent the funds. Thirty days after receiving these reports, the Act requires agencies to publish not necessarily the recipient reports themselves, but “the information submitted in reports” publicly available on “a website.” That is, not necessarily on Recovery.gov or the board website (if they are separate sites). Can we be assured that the full text of all recipient reports will be published? And can we be assured that they won’t be scattered across dozens of sites, but placed in a central and easy to access place?
3. Finally, how deep will the data go? The Board website mandated in the Act only requires the publication of “detailed information on Federal Government contracts and grants that expend covered funds” in the same fashion that USASpending.gov now employs. (Emphasis added.) The problem is that a federal grant could be $10 million to Miami from DoT for roads, and that’s it. There is no requirement that the city then publish its contractors and subcontractors on the Board site. This is a big gap; if the only that must be disclosed on the Board site is the contract or grant award, then the trail will run cold very quickly. That said, there is a requirement for contractor and subcontractor reporting, but it comes in the recipient report mandate I explained in question 2, and like I said, there is no guarantee that we will get the full report data, nor that it will be centrally housed. Can we get that assurance?

As Recovery.gov and any other official stimulus accountability sites come on line, StimulusWatch.org and other will be looking to make the data useful to citizens. We can only do this, however, if the administration keeps its pledge to be transparent. Mr. President, just give us the data.

Sorry, this has nothing to do with tech policy, but I just had to comment on Eugene Robinson’s latest column in the Washington Post singing the praises of an unbounded stimulus plan. For those of you not familiar with Robinson’s work, you’re really missing a treat. Eugene Robinson and his colleague Harold Meyerson compete on a weekly basis in the Post for the title of “World’s Most Rhetorically Outrageous (and Economically Illiterate) Newspaper Columnist.”  It’s a heated race. These guys really know no shame. [Note my earlier essay about Meyerson’s effort to equate media reinvention efforts with terrorism!]

Anyway, in his latest column, Robinson firmly establishes himself as the new leader in this ongoing race with the following gem:

The House of Representatives loaded up the bill like a Christmas tree as powerful Democrats found room for their pet projects. This was a good thing, not an outrage. Hundreds of millions of dollars for contraceptives? To the extent that those condoms or birth-control pills are made in the United States and sold in U.S. drugstores, that spending would be stimulative in more ways than one.

Oh, wow. Just wow. Taxpayer funding for birth control as a stimulus to drugstores and domestic pill makers. By that same reasoning, “stimulating” the sale of sex toys would benefit adult bookstores and the domestic dildo industry.

Hey, why not. The more spending the better, right? Who cares if we’re bankrupting our children.

Some sensible thinking here about broadband pork stimulus plans from Saul Hansell of the New York Times. In his piece on the NYT Bits blog this week, “Does Broadband Need a Stimulus?” he argues that people should stop grumbling about the “relatively small sum” of $6 billion that the new administration has proposed for wiring rural areas and urban centers. Hansell argues:

This also seems to be a rather sound policy choice because, as I look at it, the noise about a broadband gap is hooey. With new cable modem technology becoming available, 19 out of 20 American homes eventually will be able to have Internet service that is faster than any available now anywhere in the world. And that’s without one new cable being laid. That fact hasn’t prevented a lot of folks involved in telecommunications policy from calling for a lot of money to be spent on backhoes and cable riggers. For example, the Communications Workers of America and the Telecommunications Industry Association called for $25 billion in subsidies to network providers as well as tax breaks. The Free Press, a group that advocates for media diversity, recommended spending $44 billion, with an emphasis on subsidizing companies to compete with existing cable and phone companies. Running a new fiber-optic cable to every American home may well increase competition in broadband providers, but it isn’t needed to deliver high-speed Internet service. Current cable modems use just one of the more than 100 channels on a typical cable system and can often offer speeds of 16 megabits per second or more. The next generation of modems, using a technology called Docsis 3, allows several of those video channels to be combined to offer what ultimately can be Internet service as fast as 1 gigabit per second — 10 times faster than is offered in Japan, which generally is regarded as having the fastest broadband infrastructure.

What is most significant about Docsis 3 is that it turns out to be quite inexpensive to upgrade existing cable systems to use it. As a result, Comcast and other cable systems are already deploying the technology rather quickly. In other words, with no government intervention, the country is going to have the infrastructure very soon to provide almost everyone with the fastest possible Internet service. To be sure, Verizon and, to a much lesser degree, AT&T, are already building out fiber-optic-based networks that compete with the cable companies in broadband, voice and video. Clearwire, a venture that includes Sprint, is building a wireless broadband network. Certainly, competition often lowers prices and increases choices. But it is hardly clear that the country would get an adequate return from subsidizing what is essentially duplicate capacity.

Amen to all that. Plus, Hansell might have cited the 70 years of experience we have with universal service programs, which have proven to be the very model of waste, fraud, and abuse that many tax-and-spenders claim they now wish to avoid. Moreover, those inefficient subsidies have discouraged competition in rural areas. If we only subsidized McDonalds in rural area, do you think Burger King, Taco Bell or any other fast-food chain would have ever come to town?  But that’s basically the way this racket has worked in the telecom world for years.

UPDATE: I’ve created a Google Group for this project. I hope you’ll join it and help us build this tool.

Last Thursday I asked for help creating a site that would facilitate crowdsourcing the task of prioritizing the 11,000+ projects proposed in the U.S. Conference of Mayors’ $73 billion “Main Street Economic Recovery” stimulus plan. The point of doing this is to help President-Elect Obama keep his promise that any stimulus spending will be directed at critical infrastructure, and not pork. Roads and bridges and schoolhouses are infrastructure, but dog parks and tennis centers in wealthy neighborhoods probably don’t count.

Software developer Kevin Dwyer stepped up to the plate, took the mayors’ report, and parsed out the projects into an SQLite database. You can find the database here and Kevin’s take on what he did here. Now that we have the data in an easy-to-remix format, I’d like to ask for your help developing the backend for the site.

Going forward I can offer graphic design and copywriting to the project, as well as cat-hearding, which are my comparative advantages. What I don’t have are the technical chops to code the backend. If you are a developer, or know someone who is, and might be willing to help, please read on. The functionality I’d like the site to have is a lot like what WashingtonWatch.com offers. Each proposed project would have its own item page. That item page would list the project name, city and state, cost, and estimated number of jobs it would create, all of which are included in the database. Then each item page would have a wiki section where users could write (hopefully) neutral POV descriptions of the projects to put them in context. Under that there would be a comments section where users could trade their opinions on the merits of the project. (Perhaps these could be threaded, maybe using Disqus.) Finally, and importantly, each item page will have an up-or-down voting mechanism that will let users register whether they think the project is critical infrastructure or not critical infrastructure. This voting is what will let us rank projects from critical to porcine.

(Here is a sketch of the interface with notes. It’s a lot like an individual bill page on Washington Watch.)

Now, apart from search functionality, we would have to offer easy browsing for folks to find projects that interest them. I think the home page should offer a link to search by city and state. Clicking on that link should offer a list of states. Clicking on a state should offer links to all cities in that state, as well as a list of all projects in that state in case a user doesn’t want to drill-down any further. Clicking on a city will display a list of all projects in that city.

Each of these lists I’m describing should be sortable by name, locality, cost, and estimated number of jobs created. That way someone can click on a state then sort by cost so they can see the most costly projects first. On the home page there should also be a way to browse all projects in the country ordered by cost. Another possible sorting option might be how a project is ranked by users.

So what do you think? I’d love to hear any thoughts or criticism you might have on this proposed interface. I’d also love to hear any ideas of the best way to technically implement this (especially if you’d like to volunteer to help out). I’ve been told one way to do this is to use MediaWiki and create a page for each project. That sounds good but I’d like to make sure we have the ability to rank and sort like I’ve described. Is that possible? I’ve also seen Pligg, a Digg clone, which might do the trick, but it while it has commenting and voting, it doesn’t have a wiki component. Finally, we could beg Jim Harper to let us use his Washington Watch software, but it’s custom-made and I think it’d probably be easier to use something off the shelf. I’m sure there are other ways to do it and it would be great if we could hash them out here. Thanks for your time!