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One of the joys of being a grandparent is that you get to watch the 1939 film version of the Wizard of Oz all over again. And again. And again.
Still, for those of us who tromp the halls of tech public policy in Washington, there is a potent lesson in the Wizard's booming refrain of "Pay no attention to the man behind the curtain..." when the great Oz turns out to be a fraud. A lession that played out this week at the US Department of Justice.
For those who have been on vacation, this is the week in which we hit a new all-time high for unemployment in the US, and the stock market again began to tank with no end in sight. The FBI announced that mortgage fraud is so rampant (and growing) that they simply can't keep up. Someone (possibly North Korea) launched a cyber attack against the computers of the US Treasury, the Secret Service, the Federal Trade Commission and the US Department of Transportation. Spam is out of control, as is identity theft.
Oh, and the US Department of Justice announce that it would launch a new anti-trust investigation into cell phone companies seeking to determine...ummm, something. Or maybe nothing. They aren't sure, and probably won't be until they have spent untold millions of our dollars. They think, just maybe, they may decide that cell phone companies have too much power, and want to investigate that.
Understand, no crime has been committed. In fact, when Sen. Herb ("I spent eight trillion dollars of your tax dollars and all I got for it was this crummy tee shirt") Kohl launched a similar investigation of the cellular companies, he could not find anything wrong. He did, however, ask the the Department of Justice to launch an investigation of these non-crimes.
The reality is that the US cellular industry, for all of its faults, remains one of the best things about this country. It is highly competitive. It offers an incredible array of services. It has continued to innovate, to improve services, to improve coverage, and to lower prices over the past two decades.
If you've read my columns in print publications (including my Bleeding Edge tech columns), you'll know that I am no particular fan of the cellular companies. For the past 15 years, I have devoted two to three columns per year to berating those companies for their junk phones, goofy policies and bizarre advertising claims. But I do so out of love, not hate. Like a wayward child, I chastise them when they are wrong but otherwise love them for who they are:
The very best cellular services in the world. Innovators. Successful private companies that bring value to the nation and to their shareholders. And companies that just might, if we don't let their competitors use cheap political games to bring them down, solve the problem of ubiquitous broadband in rural America.
In today's challenging environment, the DOJ intention to investigate these companies based merely on speculation and gossip is an outrage. An outrage that the White House should put an immediate end to, but probably will not.
As for me, I'm saddened to think that the Justice department I once thought was the great and powerful OZ -- an agency I believed was committed to justice and the law -- looks more and more like a political hack in a cheesy suit pulling levers behind a curtain.
Time to go back to Kansas.
There's an old business adage that those who fail to plan are planning to fail. The adage came to mind this week as I looked over the untold thousands of pages of comments filed with the FCC as public input to their Congressionally-mandated "National Broadband Plan."
Because for the most part, it seems that the usual cast of characters filed the usual comments, most of which have been filed as "comments" in every FCC proceeding for the past 15 years.
The companies want out from under regulations. The telecom attorneys want more contentious policies that will earn them bigger fees. The whack jobs on the left want to give everyone everything for free, or at least to ensure that no company ever makes a profit. The whack jobs on the right want to know what happed to the Moral Majority.
The problem is that none of these add up to a coherent plan. None of them is even actually very useful in creating a plan.
We should have had a national broadband plan back in 1993, when the commercial Internet was first created and the contracts let to private companies to develop it. Or in 1995, when we created the massive update to the nation's telecom laws. Or even in the late Nineties, when we flailed around trying to pretend that broadband over telephone copper wires should be regulated differently than broadband over cable copper wires.
All that said, it would be delightful if what we got was a real plan from the FCC for the future of broadband. One with research, and a mission statement, and goals and strategies and a budget.
That's not what we will get from this process, for any number of reasons. First and foremost, there doesn't seem to be anyone at the FCC who knows what a real strategic business plan looks like. If they did, we would have had one by now. Second, all of the input is being made by inside-the-beltway lobbyists and pundits. And third, by the time the thing is finally flopped on the table before Congress like a dead fish, there won't be any money left to implement it.
I don't envy Julius Genachowski or the other commissioners their task, but neither do I have much sympathy for them. What they will be driven to produce will be a wish list rather than a plan. It will seek to balance the competing interests of all the parties in a way that most pleases the political lords in Congress and the administration. No one gets more than their fair share, everyone gets a little something. Just balanced enough to avoid making anyone too angry. Merry Christmas to all, and to all a good night.
That's not a plan, because it will fail to set substantive goals or outline real strategies to reach those goals. If it did so, it would raise a ruckus among the lobbyists and self-appointed advocates because goals and strategies have to be based on real facts rather than political dogma.
So we will fail to plan; and thus plan to fail.
So when the dust finally settles, the Broadband provisions in the American Recovery and Reinvestment Act of 2009 are actually pretty good.
There is some money, to be doled out by the Department of Agriculture for rural broadband projects, and by the Department of Commerce for innovation. Not a lot of money, but that may be a good thing.
There is a requirement that the FCC develop a national broadband plan within a year. A reasonable time frame and a good project that falls well within the mission of the FCC. I look forward to reading what is proposed, and throwing in a few ideas of my own.
And there is a requirement for a broadband mapping project, which can only lead to better coverage of broadband.
Of course, I also like it because it dropped all of the lunatic language about mandatory open access and network neutrality (which in case you missed it, has once again morphed to mean something different than it used to). That kind of nonsense rhetoric has no place is a serious discussion of broadband policy, something that even Google now seems to have conceded.
So I look forward to the year ahead, to the evolution of a national broadband plan, and to an improving economy. And, if there is indeed a good in heaven, a decent wine crop worldwide to help produce the Cabernet Sauvignon I desire to drink while I read the various proposals and platforms.
I've stayed out of the cat fights over the American Recovery and Reinvestment Act -- the highly heralded economic stimulus package -- for three reasons.
First, in spite of the invective you may read and the famous quote by Mark Twain ("Suppose your were an idiot. And suppose you were a member of Congress. Oh, but I repeat myself."), Members of Congress are not stupid. Most of them are hard-working, dedicated people trying to do their best for their constituents and their country. And while they do make some horrible policy mistakes, the bill they are passing deserves to be taken seriously.
Second, all they have done is authorize the spending. There is still a matter of finding the money to actually do it. And while a $1 Trillion price tag seems staggering, it is unlikely we will spend anywhere near that much. Particularly because...
Third, we are already on our way out of the recession, IMHO. I have a very accurate barometer of the economy here in the Blue Ridge Mountains of Virginia, and my barometer says things are already mending.
I keep a close eye on Sunday morning breakfasts at the Hawksbill Diner. For those who do not live in the valley of the Shenandoah River, the Hawksbill Diner is legendary. A tiny, converted convenience store that has been around almost as long as the Blue Ridge Mountains, the Hawksbill DIner (named for the river that flows nearby) serves a fine breakfast. You can see almost all of your neighbors there of a Sunday, unless you wait too long and the tourists take all the tables.
The point is that last fall people would come in (you have to have breakfast at the Hawksbill, then go to the WalMart to see all your neighbors, or you are considered unsociable here in the valley) but would only order a biscuit and coffee, not a real breakfast. Times were hard and people were scared.
Today, the breakfast trade is just fine at the Diner, and at WalMart as well.
That's how I know things are improving. People are eating breakfast on Sunday Mornings.
And I know that the stimulus bill, while as a conservative libertarian I am not happy about, will not mean the destruction of all things American. It may actually work, and may actually do some good. I know this because I have actually gone to the Thomas web site at the Library of Congress and read all 800-some pages of the bill.
Which is something virtually none of the media people reporting on it, the radio show hosts who lambast it, or the so-called advocates who swoon over it have bothered to do. Reading legislation before you pass judgement on it -- what a concept!
Long ago and in a different war, I joined the military. It was part of our family's tradition of service to our country, and it was a responsibility I took seriously. Including qualifying as an expert marksman, even though it was not my job to carry a rifle.
I learned that on a military firing range, the expression "Maggie's Drawers" was used to indicate that you had completely missed the target.
The same term can be used to describe our approach to bringing broadband to all Americans. We have been so focused on phony issues and partisan finger-pointing that we have completely failed to even see where the real target lies.
Yet the data is consistent, clear and compelling. This nation, which once boasted a literacy rate of 99 percent, has seen that rate falling sharply. One in four high school students is a dropout before graduation -- one in three among black and hispanic kids. These kids will be forever consigned to low-income jobs and lives. And, the data says, low-income, low-education Americans don't use the Internet.
For some reason, we continue to pretend that the problem is a lack of infrastructure. Even though we can now get a broadband signal of some kind to more than 99 percent of all homes and businesses in America. Even though the cost of our broadband is below the world average. Even though we continue the amazingly rapid deployment of fiber and other advanced broadband technologies.
The truth is that we can't handle the truth. We'd rather bluster and blather about "competition" and "duopolies" and "network neutrality" than face the harsh reality that we are failing one-fourth of the American population with our bad policies and partisan bickering.
Already, the Congress is lining up to announce a new slew of bills to manipulate, regulate and complicate broadband in this country. Not one of those bills even mentions the critical issue of Digital Inclusion, or proposes a program to help people learn the literacy and computing skills they will need in the 21st Century.
Perhaps solving this very real problem is too difficult. Or perhaps it is not politically expedient. Or doesn't raise money and support for re-election.
But I have watched as we spent three years wrangling over the non-issue of "network neutrality." I have seen a decade of repeated efforts to force broadband's square peg into the round hole of 19th-Century telephony regulation. I have watched as greedy state treasurers lick their lips over the prospect of taxing Internet access, even though this would only make access less accessible to lower-income families.
In an industry obsessed with social networking, videos and making a fast buck, we've paid scant attention to the fact that most people who don't use the Internet are disinterested because there is nothing on the Internet they want or need. In an industry of rock stars and overnight sensations, we've left consumers waiting by the curb.
When it comes to solving the real and tangible and proven problems that confront us, or moving toward solutions that will actually make ubiquitous Internet use a reality, we've come up Maggie's Drawers. And until we start basing broadband and Internet policies on reality rather than political dogma and wishful thinking, we will only see our efforts continue to go astray.
President-elect Obama has been largely silent on who and what this new position of Chief Technology Officer for the government will be, but the basic idea is a good one.
Unlikely to be a cabinet-level post, the Federal CTO is also unlikely to be a policy-making position -- the federal government already has plenty of policy wonks within the Department of Commerce and the Federal Communications Commission, and there is little evidence that these are not sufficient to the task of setting policy and regulation. Where these are not enough, there are always the committees in the House and Senate to fill the gap.
Where the CTO would be a welcome addition to the Administration and to the Federal Government will be in four specific areas:
- Advancing the security of government technologies. The last decade has been an unending litany of failures and gaffes in this arena -- failing grades on cyber-security, lost laptops, security breaches, and more. Someone needs to bring a greater measure of consistency and security to the computer and telecommunications systems of the entire Federal government, and the CTO is a logical candidate for the job.
- Advancing the cause of eGovernment. President-elect Obama has correctly identified a problem in how information about our government is consistently and transparently communicated to Americans via the Internet. If you don't believe that, try using the FCC's search system to find a document on any subject at all. Try to find out from the Department of State how much liquor you can legally bring into the US from an overseas trip (answer: it depends...). Or find the hearing schedule for Congress on any given day (hint: skip the Congressional pages and go to C-Span's web site). The people deserve better than this, but it will take planning, commitment, and a steady CTO to achieve it.
- Bringing order to the government technology procurement system. Letting every agency choose what they want has left the government with a series of expensive, proprietary solutions that often don't work. From the new computer system for the FBI to the antique systems in the Treausry Department, there needs to be a better job of procurement policy and oversight throughout the government.
- FInally, assessing the technologies and issue technical guidance so those within the government who are not geeks by nature will have some idea what is out here in the real world and how it can be used. Keeping pace with evolving technology is a full-time job, and most servants of the people just don't have time to keep on top of it while still doing their full-time jobs. A CTO could help.
All that being said, neither the president nor the American people will be well-served if the person selected to become the government's CTO is simply another political hack with an agenda. If you want the position to be effective, it has to be clean. Or at least as clean as any federal appointment can be.
That automatically rules out just about any of the executives from Google, Microsoft, the major telecom companies, the major cable companies or Cisco Systems. Fortunately, there are still lots of excellent choices available from within the ranks of technology who won't come to Washington with an axe to grind or an agenda to push.
Personally, I would opt for someone who is a little skeptical of the current wars over Internet governance. Senator Ron Wyden of Oregon, for example. Or Declan McCullough over at CNet. Or even David Young at Verizon. None of these would want to take the job, which is another reason why they would be well suited for the task.
Whoever is chosen as the government's CTO, and whatever the final job description, I wish them Godspeed and good luck. It's a tough job that desperately needs doing.
Those who demand the regulation of broadband -- open access rules, network neutrality rules, a national broadband plan, rate regulations, expansion of universal service, ad nauseum -- are fond of claiming that what we must fear most is the emergence of a monopoly that controls all of broadband. One mega, evil networking company that seeks to control what we see, how we see it, who can be on it, and who can't.
They speak of monopolies, and duopolies, and whatever-big-word-we-can-think-of-to-scare-you-opolies, and point their long, sanctimonious fingers at leading network operators as likely villians.
Which is proof that those who will not learn from history are doomed to become progressive liberal telecom pundits.
Just for the record, free markets abhor monopolies. In a free market, unfettered by government interference, the marketplace will move quickly to quash possible monopolies through innovation, competition and consumer choice.
How, then, do monopolies get created? By governments, of course. Only with the direct intervention and deliberate cooperation of the government can monopolies form or continue. A case in point? Monopoly cable franchises.
But if we are talking about how broadband might become a monopoly, we have an even better example. Once upon a time there was a telephone company called AT&T (which, for the record, is not the same company in any way as the current one that carries the AT&T brand name). AT&T the telephone company did not set out to become the monopoly that had to be broken up in 1982. It followed a process, set by the United States government and agreed to by the officers of that company in what, in retrospect, turned out to be a deal with the devil.
It began with the patents, and with the confusion and meddling at the Patent Office that gave the lion's share of the telephony patents to a single, pre-selected winner. Then, around the time of World War I, the telephone system was declared so critical to the security and future of the US that it was nationalized. Not many years later, the government sought to ensure low rates, and so introduced rate regulation for telephony -- including cross-subsidizations, government supports and other artificial mechanisms. The final step was to make the telephone company an instrument of social policy by implementing universal service and minimum service mandates.
All of which must sound eerily familiar to those attempting to battle for consumer choice and free markets today. The Patent Office is an ungodly mess, giving power hither and yon based on shifting definitions and interpretations. In the wake of 9-11, we have the Internet declared to be essential to US security and the future. So-called consumer advocates are demanding telephony-style rate regulation. And Congress is trying to expand the mega-billion universal service program to broadband.
How much of this is supported by the networking companies? None. How much do they want to return to the old days of monopoly operations? Not a bit.
Which again begs the question: if it is not the networking companies pushing us down the long, slippery slope that could lead to a monopoly, who is it?
I'll take a wild guess that it is the same bunch of academics, policiticians and pundits who are pushing hard to put all the pieces of a monopoly in place -- the net neutrality/open access/rate regulation crowd. They are not a bit interested in letting consumers in a free marketplace keep us off of that path, and are pushing as hard as they can to create the government co-conspiracy that will enable them to choose which monopoly company will succeed.
Which is why I can't and won't ever support them.
Over on GigaOm, Worldwide Lexicon founder Brian McConnell has blogged about the reasons why municipal Wi-Fi has been an astounding disaster, and what can be done to fix it.
He's half right.
McConnell correctly notes that one of the biggest problems was that Wi-Fi advocates completely misunderstood who used public Wi-Fi. He notes that "muni W-Fi proponents have misunderstood how the Internet is used in public spaces, primarily by assuming that people who can afford laptops are somehow unable to afford Internet access."
That's one of the reasons. You can also add lack of planning, poor reception, technical obstacals, abysmal security and the "somebody else will pay for all this" mentality that seems to follow these projects, but I won't quibble.
McConnel then goes on, however, to state that the problem of serving the poor and minority could be handled by giving anyone who can't afford broadband a cell phone data plan and a data-enabled cell phone. McConnel elegantly puts it this way:
"It seems reasonable to me to require mobile operators -- as a condition for siting cell towers throughout a community -- to provide basic service to users who can't afford it."
Pardon me for saying this, but I think most municipal governments would chew off their arms rather than give up a sheckel of the loot they extort from the cell phone companies for the right to build towers. They are unlikely to give up the loot in particular to help poor people get cell phones. Still and all...
McConnell should get high marks for a good idea. He begins with the premise that public-private partnerships could be a good idea in the cell phone market, and that expanded use of data on cell phones would be helpful to some poor people. He even takes the tech community to task -- rightly, IMHO -- for its arrogance:
"Most of us who read this site take communication for granted, and frankly, have a warped view of what people outside the tech industry need. Talk to a tradesperson or someone who falls under the category of the "working poor" and you'll get a much different view of what's important (things like an affordable place to live, basic services, the means to find work and get things done)."
But McConnell's idea suffers from the same major flaw as arguments for municipal Wi-Fi. It's based on wishful thinking, not on data. McConnell must know that even poor families already have cell phones, and that plans exist to help them with "lifeline" services. Likewise, I don't think that the problem is that people can't get reasonably-priced plans for mobile communication, even if they involve pre-paid phones.
The problem remains literacy, and computer literacy. All the infrastructure in the world won't help if Johnny can't read. And that's the crushing problem that is holding back the national adoption of broadband, more than any other single factor. Not deployment. Not cost. Not competition.
Literacy.
McConnell is on the right track -- public private partnerships, helping poor people become economically independent, and helping them to upgrade to better plans as they can afford them. He should be encouraged to take the next steps to flesh out his ideas with more and better data.
And if they are thinking clearly, the mobile communication companies will help fund that effort.
The OECD has again released a ranking of broadband penetration worldwide, and once again the United States is ranked 15th in the world, somewhere slighly below the Grandy Duchy of Luxembourg.
You can already hear the gears grinding. Disreputable blog sites are gearing up to use this factoid to again attack America's broadband industry. Pundits are pontificating, politicians are blustering, and the lunatics on the left are again DEMANDING that the government seize control of broadband -- or at least tie it up in 19th Century-style regulations. Woe is U.S., again.
But before this nonsense goes to far, will someone please actually read what the report says, instead of simply swallowing the OECD press release? Because even the most cursory glance at the data would make any rational person ask, "Are they just making this stuff up?" And the answer, sadly, is "Yes."
Here's what's interesting about the OECD data:
- It measures broadband adoption, not deployment. The data presented isn't about where broadband reaches, but rather how many people are subscribing to the services. Even then...
- The U.S. data is not from December of 2007, as advertised, but from 2003. Strangely, when it comes to the data for household subscriptions to broadband, the figure is frozen at the 2003 levels of fewer than 20 million. But it gets even worse...
- It's not even data. The U.S. figures were, according to the authors, an "OECD estimation based on company reporting." You have to wonder what company data they used, since current US estimates are that some 60 percent of the 105 million US households now have broadband. But then...
- They fudge the figures. The OECD numbers allow Korea to include people whose broadband access is via cell phone, but the US numbers don't include that. Nor do they include the nearly 12 percent of the U.S. online population -- that would be another 7-million plus Americans -- who use Wi-Fi connections. Include some things, don't include others, and voila! The next thing you know, lower Botswana will have better broadband penetration than the U.S.
The rest of the so-called data is equally bad. When they compare prices from country to country, they allow some countries to use figures that include long-term discounts that don't generally apply in the U.S. And they fail to note where countries heavily subsidize the cost of broadband to artificially make their numbers look better.
The OECD itself -- feeling bee-stung by the tidal wave of criticism for its bogus "reports," has coyly noted in the report that the information should not be used to make conclusions about public policy, and that the report may contain some inaccuracies. But you won't find any such statements in press release touting the report, or in the "conclusions" it presents that urge governments to push for "competition" and "open access." Those latter recommendations, it may be noted, are based entirely on the political prejudices of whoever wrote the news release -- the recommendations are neither mentioned nor supported in the data.
The OECD study is junk science, but it does provide an opportunity to remind those of us working in broadband public policy of three key rules:
- Some people just plain hate America, and will use any bogus data or flimsy excuse to humiliate this country on the world stage -- or worse, encourage us to adopt really, really bad policies -- in order to gain some advantage over us on the world stage. I would hate to think this applies to the OECD, but one has to wonder why, year after year, they continue to flaunt phony studies with bad conclusions that make the U.S. appear to be something other than a world leader in broadband.
- News releases announcing studies almost never match the data. The Wall Street Journal concluded this in an article last fall, noting that in nearly 90 percent of cases they studied the data did not support the conclusions reached in the news releases.
- It's about adoption, not deployment. The United States clearly has some work to do to bring the rest of our population online. But we won't achieve that by focusing on broadband deployment, or by continuing to attack broadband infrastructure companies. We can only do that by addressing the reasons why some people aren't using the Internet -- primarily lack of education, lack of computing skills and a lifestyle in which Internet access is not relevant.
The knee-jerk pundits and politicians who can't be bothered to actually read the studies, or who base their positions on press releases and bluster, will eventually look as silly as they truly are. We can only hope that happens before they adopt needless, destructive and badly-written legislation that may actually make our national broadband as bad as the OECD studies try to make us appear.
As the end of his term as Chairman of the FCC looms, I am becoming more comfortable with Kevin Martin and his style. In fact, I'm downright tickled with his recent handling of the "network management" flap and its demonstration of how well the system works.
The furor over using forged TCP reset packages to shape traffic on Comcast's network clearly presented a legitimate question: To what degree are such actions in the best interests of consumers, and to what degree do they violate the spirit and letter of the Principles adopted by the FCC in 2005?
The way the process is supposed to work is that such questions are first handled directly between the consumer and the broadband provider, based on terms of service and commercial agreements. When this first step does not resolve the issue, it gets elevated to the FCC. Which it did.
Here's where things get sticky, because this legitimate issue of consumer rights got tangled in the efforts of a lunatic minority to force the FCC to adopt new and outrageous regulations for the Internet. This minority of roughly one one-thousandth of one percent of Internet users in the US sought to use this legitimate inquiry to bully the FCC into changing its principles into hard regulation. This would then enable a handful of lobbyists to "game the system" whenever they want by endlessly accusing broadband companies of "violations."
The FCC knew there was a potential for the Principles to be abused. That's why they clearly stated at the time of their adoption that the Principles did not and would not be regulatory rules. This way, the Commission has the flexibility to address each situation as it occurs. It was a wise move in 2005, and remains so today.
So the issue is taken to the FCC for consideration, and things get tricky because the pro-regulation minority was howling for a one-size-fits-all regulatory quick fix they could more easily use for their own political purposes. Kevin Martin had to weave his way through this minefield.
But then things spun out of control at Comcast.
I've worked for enough large corporations, both inside and as an advisor, to know that things can pile up during a crisis. Good intentions turn bad, innocent actions are in retrospect portrayed as sinister, and the whole organization is left wondering what the heck happened. If you want proof, just consider the Exxon Valdez oil spill.
Whatever the reason, it appears that Comcast first tried to duck the issue, then prevaricate its way out of the issue, and then compound its public relations problems by derailing the FCC's hearing in Boston, filling the public seats with homeless people.
Which, of course, was the cue for Congress to open its own witch hunt over the issue.
In short order, Chairman Martin faced the task of protecting the integrity of the consumer protection process from both the raging minority of pro-regulation loons and the Congress; while dealing with the questions of policy that were presented in the first place; while keeping intact the consumer Principles enacted by the FCC; and providing support for the legitimate needs of broadband providers to manage their networks. Oh, and punish the guilty if there were any.
It wasn't easy. It took guts, a steel-reinforced loin cloth, a commitment to principle and a belief in the power of the process to listen to the loons without over-reacting, stare down Congress and push to a resolution. But in the aftermath, here's the scorecard:
* Everyone got their day in court in a hearing before the FCC.
* The Commission clearly upheld the need for and benefits of network management, refusing to buy into the vision of a "wild west" internet ruled by anarchy.
* Chairman Martin held his own before Congress, outlining the policies clearly.
The process is not complete, of course. Martin has indicated he will take action against Comcast for its behavior, though he has not specified what action. And there remains the question of how this might impact other service providers and their efforts at traffic shaping.
There are other benefits as well. Consumers learned more about how a handful of users are taking more than their fair share of bandwidth. We all learned more about the progress being made to accommodate file sharing on broadband networks, through such efforts as traffic shaping and P4P. And the process drew attention to the need for more transparency in commercial contracts and user agreements, so that both sides more clearly understand the terms of service.
Best of all, the process was validated. It works, and we don't need draconian regulation of the Internet to assure that problems can be handled effectively.
Kevin Martin, the lame-duck Chairman of the FCC, refused to be bullied by either the loons or the Congress, His performance through it all was calm, deliberate and purposeful. And that's not bad at all.