The BTLJ Podcast team sits down with Berkeley Law Professor Tejas Narechania to discuss his forthcoming article, “Convergence and a Case for Broadband Regulation.” In the interview, Professor Narechania identifies the consequences of the outdated regulatory scheme for broadband services that exists in the United States. He also proposes a system involving broadband rate regulation as a solution to the problem. This interview was recorded on November 10, 2022.

Podcast Transcript:

INTRO

You’re listening to the Berkeley Technology Law Journal Podcast. I’m your host, Eric Ahern.

With COVID-19 pushing many facets of everyday life online, access to affordable and quality internet services has become essential. However, current telecommunications statutes have lagged behind technological advancements at the cost of consumers. 

In today’s episode, our colleagues Yavuz and Joy sit down with Berkeley Law Professor Tejas Narechania to discuss his forthcoming essay, “Convergence and a Case for Broadband Rate Regulation,” which proposes broadband rate regulation as a regulatory solution to this problem. This essay’s novel study shows that consumers served by monopoly providers pay significantly more for worse internet services. However, Professor Narechania argues “this data also suggests that broadband rate regulation, where it exists, helps move rates and quality closer to competitive levels.” 

Professor Narechania is the Robert and Nanci Corson Assistant Professor of Law here at Berkeley where he writes about (and teaches courses on) telecommunications regulation, intellectual property, and other subjects.  He is also a Faculty Co-Director of the Berkeley Center for Law & Technology. His projects have been cited by the White House, in the work of the Supreme Court and the federal Courts of Appeals, as well as in the New York Times and the Washington Post, among other venues.

I’m Eric Ahern and I hope you enjoy the conversation. 

[music]

[Eric] 0:12

You’re listening to the Berkeley Technology Law Journal Podcast. I’m your host, Eric Ahern.

With COVID-19 pushing many facets of everyday life online, access to affordable and quality internet services has become essential. However, current telecommunications statutes have lagged behind technological advancements at the cost of consumers. 

In today’s episode, our colleagues Yavuz and Joy sit down with Berkeley Law Professor Tejas Narechania to discuss his forthcoming essay, “Convergence and a Case for Broadband Rate Regulation,” which proposes broadband rate regulation as a regulatory solution to this problem. This essay’s novel study shows that consumers served by monopoly providers pay significantly more for worse internet services. However, Professor Narechania argues “this data also suggests that broadband rate regulation, where it exists, helps move rates and quality closer to competitive levels.” 

Professor Narechania is the Robert and Nanci Corson Assistant Professor of Law here at Berkeley where he writes about (and teaches courses on) telecommunications regulation, intellectual property, and other subjects.  He is also a Faculty Co-Director of the Berkeley Center for Law & Technology. His projects have been cited by the White House, in the work of the Supreme Court and the federal Courts of Appeals, as well as in the New York Times and the Washington Post, among other venues.

I’m Eric Ahern and I hope you enjoy the conversation. 

[Joy] 1:53

Hi, my name is Joy Lee.

[Yavuz] 1:56

Hey, my name is Yavuz Usaklioglu. 

[Joy] 1:59

Today, we have Professor Narechania to discuss about his forthcoming article Convergence and a Case for Broadband Rate Regulation. 

[Yavuz] 2:07

Thank you so much for joining us. Could you please give our listeners a brief summary of what the article is about and your motivation for writing it?

[Professor Narechania] 2:16

Yeah, I am happy to do so. But before I do, I just want to say thank you to both of you, and to the Berkeley Technology Law Journal, not only for hosting me on the podcast, but for publishing the paper. So maybe I’ll say a little bit about where the paper sits. And then I’ll talk a little bit about what the paper is about. 

So Professor Stallman and I decided that one thing that we wanted to do was mark the 25th anniversary of the Telecommunications Act of 1996, with a symposium that sort of thought about all of the changes to the telecommunications industries since 1996, and the ways in which the law has worked, and maybe the ways in which the laws have not worked. And this piece is my contribution to this symposium that we organized, and all of the pieces will be coming out in a special issue of the Berkeley Technology Law Journal. I’m so grateful to the journal for doing that, and putting it together. And I’m really so grateful to all of the authors who’ve contributed some really interesting and thoughtful, thoughtful pieces to that symposium. 

This piece in particular looks at one aspect of the structure of our old telecommunications statutes. And it looks in particular at the way these old statutes have different regimes for different industries. And those different industries tended to depend on the type of physical facility that was at issue. So we would have copper wires for telephone, we would have coaxial wires for cable, and we would have wireless spectrum for radio broadcasting and TV broadcasting. And so, you know, there’s this long tradition of having different physical facilities, and then a different type of media, and then a different type of regulatory regime. On top of that, we would have different rules for telephones and for television than for radio, and whether it was television or radio would depend on the physical facility. 

One thing that has happened since 1996 is the growth uptake and a wide amount of innovation on the internet. And one thing that I think we all know and we live with today is that the internet doesn’t care about the type of facility that you’re on and the internet doesn’t really care what you’re using your bits for. So you can access the internet wirelessly, you can access it over wire, you can access it by dial up or by DSL, or by fiber. All of these different communication platforms are used to access the internet and you use them to record podcasts, to watch videos, to send emails, to have FaceTime calls or Skype calls, or voice over IP calls. And so that convergence on to the internet has, I think, upended a lot of the assumptions that are baked into the statutory regime. 

This paper tries to pull out one particular set of problems that comes from that convergence and then thinks about what some solutions might be to some of those problems.

[Yavuz] 5:34

In the article you discuss how current cellular telecommunications policies, such as the Communications Act, conflate rules for applications with rules for transmission facilities? Why was this conflation appropriate in the past? Why is it important to have separate rules for applications and transmission facilities now?

[Professor Narechania] 5:59

So let me start by talking about the difference between transmissions and applications, and then we can talk a little bit about how the statutory structure has evolved over time or why it should evolve over time. Transmission in particular refers – what I mean by transmission is the transmission of the signals over some physical facility. The application refers to what you’re using those signals for. In telephone regulation, for example, the transmission of the signals depends on the existence of copper wires. So we have a set of rules that relate specifically to the ways in which providers set out lay fiber, or lay copper wire — lay their actual physical networks as opposed to rules that govern the telephone service rules that require that that service be, say, just and reasonable, or that rates be just unreasonable, or that the quality or the quality of the service be sufficient. That’s the distinction between the bare transmission and the applications that run on top of it. 

Another example might be the transmission of signals over cable wires and the actual video service, the set of channels that you get. You might have a set of rules that say this is how you have to transmit signals, this is the way you do it. These are the standards you have to use. But then whether or not you get Disney Channel or ESPN or CBS pertains to the particular video application that you’re getting. So in the past, we would conflate rules for transmission and applications because one transmission facility, the telephone network, would always be coupled with the same application, namely telephone service. So telephone network, telephone service.  Cable network, cable service. And so we can, whether or not it was appropriate for Congress to do this, or whether Congress wasn’t forward looking enough, is a sort of different question. But it is at least understandable. We can understand why Congress took an approach. Well, there’s this newfangled thing, the telephone, and these companies are going out, and they’re building these wires, they’re offering telephone service. We need to regulate it. We’re going to regulate the wires and we’re going to regulate the service. We’re going to make sure that the wires are laid appropriately and that they’re not dangerous and that people aren’t being charged too much and that the quality of the service is adequate, everywhere you live.

Now, as I said, we have a system where transmission is internet transmission and the applications are a bunch of different applications. So you might subscribe to a service that uses cable wires, but you’re using it in order to make voice calls or make FaceTime calls. And so that tight connection between a specific sort of transmission facility and a specific sort of application doesn’t exist anymore. We need to think more critically about what rules we want for transmission, namely, internet or broadband transmission, no matter whether or not that transmission occurs over a telephone wire, or a cable wire or wirelessly. What are the rules that we need to have for certain applications? Do we need certain rules for cable channels or for telephone service? Or for voice channels? No matter whether or not that is being offered by a telephone company, or it’s being offered by Apple, or it’s being offered by Microsoft via Skype. What are the different rules that we want to have for those different classes of service not based on whether or not you accidentally happen to be using copper wires, for example.

[Yavuz] 9:57

I’m really curious about how the FCC determines whether there’s effective competition.

[Professor Narechania] 10:03

Yeah, so good question. Let’s back up a little bit, because it’s probably worth knowing a little bit about why effective competition is important here. So one thing I just said is that it is, it’s more, it’s important now to think about having separate rules for applications and transmission facilities. And so one thing that I want to think about that I focus on in this paper, in this project, and that we should maybe – I’ll just come out and say, one thing that I’m worried about is competition among different transmission facilities providers. 

If you have access, and again, in particular to the internet, via say, Comcast or Charter or AT&T, one thing that I am interested in is whether or not there is effective competition in that market for transmission. That is, can you choose between Comcast and Charter and AT&T? Or can you choose only one of them? You as a consumer. And if you can choose among lots of them, what does that mean? And if you can choose only one of them, what does that mean? And so the reason this is important, again, going back to the old model of when applications and transmission facilities were conflated, really, at the very beginning of the statutes, we conceived of these networks as natural monopolies. And so we thought each one of these services was a natural monopoly, that the physical facilities were a natural monopoly and then, as a consequence, the application that you would get on top of it would also be a monopoly service. That, you know, it’s a natural monopoly to lay telephone copper wire and so we’re going to regulate telephone service, the application, as a monopoly: do rate regulation, service specification, all the things that you do when you’re regulating a monopoly. 

Now that we’ve moved away from that model, we’ve moved away from that natural monopoly model, we’re starting to recognize the fact that the internet is upending all of this. We’re starting to recognize that there actually is, in fact, lots of competition for telephone service. You have lots of options. Not just your local telephone provider, but also Voice over IP, also Vonage or Skype or FaceTime or whatever. We’re starting to deregulate some of those things at the application layer. There’s a lot of competition, and so we can deregulate it. We might also deregulate things at the transmission layer if we thought there was a lot of competition. If there’s not a lot of competition, then there might be value in thinking about ways to regulate providers at the transmission layer. What I do in the paper, getting back to your question about effective competition, is look to a related but distinct statutory scheme that’s specific to cable TV. So Congress and the FCC were thinking about this problem in the context of cable TV. The statute that Congress designed is a statute that gives the FCC and local entities the power to rate regulate where there is not effective competition. And so now your question is okay, how do we know whether or not there’s effective competition? How do we measure that? The statute sets out four tests, which if any of them are satisfied, allow the cable providers to get out of the rate regulatory scheme. 

So the first is what’s called the low penetration test. The second is the competing provider test; if there’s competition. The third is a municipal provider test; that is that your competition is from a municipal provider. And the one that I focus on in the paper is the local exchange carrier test. 

So local exchange carrier is a phone company. Basically, what the local exchange carrier test does is it asks whether or not you, the cable company, are facing competition from a phone company? And how does that happen? Well, what happens is AT&T, the phone company, will upgrade its networks, maybe they’ll deploy fiber, they’ll have a network that has enough capacity that it can offer its own cable TV service. And if it does that, then you, the cable company, won’t be regulated anymore. Because there’s enough competition. Where there’s not competition, we regulate the rates to make sure you’re not charging customers monopoly prices. But if there is competition, then we don’t regulate the rates anymore. 

What’s interesting about this test is that it ends up being both over inclusive and under inclusive in odd ways. The thing that it does react to is a service like AT&T TV, what I just suggested. AT&T deploys a new fiber network, provisions a TV service over that network, voila, you have two competing cable TV services. The thing that it does not react to is Netflix or Hulu. So Netflix is another TV service. Hulu offers live TV, it is another TV service. But neither one of those counts as effective competition under any of the tests. 

So that was the state of play for a while, right? AT&T would offer AT&T TV, the cable company would say hey, look now I have to compete with AT&T TV, don’t regulate me anymore. But Netflix and Hulu are growing, gaining more subscribers. YouTube TV comes on the scene, gains a bunch of subscribers, but these services don’t matter. I mean, some studies are finding that cable companies are in fact reacting to competition from YouTube TV, or Hulu with live TV. They’re offering different channel packages or trying to improve their service because, they know, they see this as competition to the application layer. So what happens? What happens next is that AT&T buys DirecTV and AT&T and DirecTV together launch a service called DirecTV Now. DirecTV Now is kind of like YouTube TV. It’s a streaming live TV service. It is not offered over a different physical facility. It’s not offered over some improved AT&T cables. It’s not offered over the DirecTV satellite network. It’s like any other streaming service: you have to use your existing internet election to get it. So, Charter, one of the cable companies, shows up and it says, “Hey look, I now face competition from DirecTV Now.” DirecTV Now is owned by AT&T, it’s owned by the local phone company. So it falls under the local exchange carrier test. “You should deregulate me.”

That presents a really interesting and difficult question to the FCC. And the reason is this: if what we care about is competition at the application layer, then DirecTV Now competes with the cable package. DirecTV Now offers different channels, Charter has to think about whether it wants to offer those channels I.t offers those channels at a certain price point, Charter has to decide whether it wants to match that price point. But there’s all these dynamics about the quality of the actual cable TV application that Charter faces because of the existence of DirecTV Now. But if you want to subscribe to DirecTV Now, you still need an internet connection. And chances are, if Charter is a rate regulated cable TV provider, then it is the only provider in your area that offers broadband that is fast enough for you to subscribe to a live TV streaming service. That is, at the transmission layer, Charter is still the monopolist. At the transmission layer, Charter is the monopolist. At the application layer, Charter faces competition. 

So now the FCC has to decide whether or not it cares more about competition at the application layer or at the transmission layer. It has to decide whether or not DirecTV Now should count as competition in the way that Netflix and Hulu have no or whether it sees this as a continuing transmission monopoly that should be regulated. And what the FCC decides is look, the thing that we care about is competition at the application layer: we’re going to deregulate Charter’s service. We’re going to deregulate Charter’s, in particular, we’re going to deregulate Charter’s cable TV service.

[Joy] 19:12

Thank you so much, Professor, for your insightful elaboration on the perils of current statutory scheme and regulations. Now, I’d like to bring the discussion forward to all those inequity issues in the current broadband rate system. 

In your article, you discuss how your novel study demonstrates that monopoly broadband carriers offer consumers significantly less value. For example, you found that where AT&T was the only provider, a package offering service for $45 for the first 12 months, and $55 per month thereafter, on average had download speeds of about 15 Mbps, which is less than the FCC’s 25 Mbps benchmark for broadband. However, where AT&T faced competition, the same package yielded average download speeds that are more than three times faster at 50 Mbps. What are the implications of these findings for the millions of Americans who lack access to a competitive market for broadband carriage?

[Professor Narechania] 20:23

Yeah, it’s a great question. And I think the bottom line… let me answer the question directly. and then I’ll back up a little bit. I think the bottom line answer to the question is, the implications for the millions of Americans who lack access to a competitive market for broadband carriage is that they are paying more for worse service. That is they are paying on average, a higher price for lower speeds, or they’re paying the same price for lower speeds –

[Joy] 20:50

Right. 

[Professor Narechania] 20:51

– which works out to, on average, on a per megabit per second basis, a higher price. So let me let me back up and sort of tell you why I even got there. So the thing that I just said was that, well, the FCC decides to deregulate at the application layer, based on its view that that application layer is competitive, but it seems really likely that if Charter was the monopoly TV provider, and DirecTV Now is the only competitor, and DirecTV Now doesn’t require some new facility to be built, then Charter will continue to be the local broadband monopolist. That is, the transmission layer monopolist for internet service. And it turns out that that’s true. 

In all of the places where the FCC deregulated on the basis of DirecTV Now, and this is the first set of results in the paper, it turns out that, effectively, those providers are the local broadband monopolist, that there’s no other real salient choice for broadband in those markets. So this means that if those subscribers wanted to buy DirecTV Now, they would still have to pay Charter money. And Charter would be the monopolist. So Charter or Comcast or Cox, depending on where you are, could charge monopoly prices. And so that’s what I was interested in. I was like, okay, well, it turns out there’s a good number of places where there are broadband monopolies – do they charge more? And some people have tried to do studies like this. But sometimes, what happens is that you end up averaging a monopolist in Michigan with a monopolist in Wyoming, against competitive service in New York against competitive service in Des Moines against competitive service in LA. 

One objection to studies like that is that, look, the cost of deploying these networks varies a lot, geography by geography, that is it’s much more expensive to deploy internet in some places and much cheaper to be deployed in other places. So these price studies need to be geographically sensitive. So that’s what I tried to do here. I look at really concentrated areas, a single town or two neighboring towns, places that are no more than a four, five, six minute drive apart, and compare prices based on competitive conditions. And so we have examples where it’s one straight road. At one end of the road, there’s competition and at the other end of the road, there’s no competition. And what I find is exactly what you described, we’re in a situation where, where there’s competition, a company like say, AT&T, for example, will charge you $55 a month, for a download speed of 15 megabits per second. Whereas at the other end of the road, you know, they’ll charge you the same price but a download speed that is three times that. 

This competition seems to be really important at driving quality or price. Consumers get much better outcomes where there is competition.

[Joy] 24:04

So with that being said, what needs to be done to address the inequality brought forth by the current broadband rate system?

[Professor Narechania] 24:14

Yeah, so there are lots of possibilities. I think lots of people have different ideas. My idea, my proposal is, and as the title of the paper suggests, rate regulation. And it’s a scheme of rate regulation that is based exactly on the scheme that I talked about, which is where you have a broadband transmission layer monopolist. And again, we don’t have to care what kind of monopolist they are, whether they’re fiber-based, copper-based…copper might not meet the standard, but if they’re fiber-based or cable-based. If they’re a monopolist, we should regulate the rates in order to make sure that they’re not charging ridiculous rates for substandard service. But if there’s competition, then let the market do it. And so one thing that I do in the paper is say, well, look, one thing that we actually have, but don’t spend enough time thinking about, is schemes of broadband rate regulation. 

In particular, when the FCC gives money to subsidize build out, to say, okay, this part of the country doesn’t have enough broadband access, “you, provider X, here’s a bunch of money for you to build a new internet, a new network to offer internet service,” the FCC attaches some strings to that money. And the FCC says you can take this money to offer service, but only on the condition that the service you offer is at reasonable rates and is of reasonable quality. The next thing that I do is look at whether or not those conditions, those rate regulation conditions, are any good at improving consumer outcomes. And it turns out that it looks like they are: that a regulated monopolist offers consumer value that is greater than an unregulated monopolist. It’s not quite as good as the consumer value that comes from competition, but it is still better. 

And so one thing that we might do in order to address the inequities is continue to try to induce more and more competition in these transmission layer markets. But so long as it is taking a very long time for us to induce that competition in these markets, we should regulate them in the meantime. That’s exactly what we did in the cable TV context. Remember that the plan there was, look, if there’s competition, there’s no authority to rate regulate. As soon as competition shows up, the authority to rate regulate is withdrawn. But in the meantime, so long because you’re a monopolist, you’re subject to these conditions of regulation. And I think we could promulgate a similar scheme here.

[Joy]  26:50

We’re really interested in hearing about how the prohibited practice of redlining ties into this issue. For our listeners who aren’t familiar with redlining, would you be able to give us a quick overview and explain how it comes into play here?

[Professor Narechania]  27:05

Sure. I can give you this sort of Wikipedia definition of redlining, which is, it’s a discriminatory practice in which services are withheld from potential customers who reside in neighborhoods classified as “hazardous to investment.” Okay, so where does this “hazardous to investment” come from? There was an old agency created as part of the New Deal called the Home Owners Loan Corporation, and the Home Owners Loan Corporation, what they did is they rated certain areas, neighborhoods, as either “best,” “desirable,” “declining” or “hazardous” to invest in. And it turns out that those definitions were based on race and class. That the areas deemed hazardous, were often deemed hazardous because the residents were black or poor. 

There’s this online investigative outlet called the Markup. The Markup did a really interesting study where they did something similar, but on a much grander scale to what I did, and compared it to historical maps, that this agency put together, of redlining. And what they found is that the places that were long ago deemed hazardous to invest in, in those neighborhoods, the service that consumers get, is much worse: they get lower speeds for the same price basically. That is in hazardous neighborhoods, the neighborhoods that were redlined, you can sort of see the long term effects of that old redlining on the neighborhoods today. That’s one way in which redlining continues to tie in to this, which is that the decisions that these agencies made decades ago, continues to cast a long shadow, even today of the quality of internet that consumers and residents and citizens living in these zones get now.

[Joy] 29:32

What are some unintended consequences or possible concerns that policymakers have with implementing rate setting?

[Professor Narechania] 29:39

Yeah, so it’s a great question and rate setting, rate regulation is kind of a regulatory pariah. People don’t think of it as something that we still should do a whole lot of. In particular, because it’s been criticized for being susceptible to regulatory capture because regulators suffer from information asymmetries when they’re trying to set rates, that there’s a potential for regulatory arbitrage, and that it can have adverse incentive effects on competitors trying to enter the market. I think all of those are valid concerns, but I think all of them can be overcome by the limited scheme of rate regulation that I have in mind here. The questions about information asymmetry, for example, that the regulator doesn’t have enough information to set appropriate rates are sort of solved here because rates aren’t being set by looking at Comcast’s books and trying to figure out okay, how much do you spend on broadband internet, and we’re going to give you a 7% profit. And as a consequence, we’re just going to add everything up and say that plus 7% is how much you have to charge. We’re just gonna look at the market, right?

We have some markets that are monopolies, some markets that are competitive. We can use those competitive markets as offering benchmarks for rates. And that’s public open information. That helps to resolve some of the concerns about information asymmetry. On incentive effects, you know, I think one of the things – I’m going to skip the stuff about regulatory arbitrage, but it’s in the paper for anybody who wants to go check it out. I’ll talk very quickly about incentive effects, which is, you know – the big objection to rate regulation is that it will deter investment. That once you say you’re going to regulate rates, no one is going to come into the market and I don’t think that that’s necessarily true. If we’re going to make that argument, it’s useful to be a little bit more precise. 

It’s useful to consider three types of investments that competitors might make. First, investments into competitive markets. Second, investments by would-be competitors into a monopoly market. And third, investments by would-be monopolists into an unserved market. For the first two, competitive markets or markets that would be competitive by new investment, this rate egulatory scheme should not matter at all. Because once a market becomes competitive, it doesn’t apply. There is no rate regulation. So it will only apply to those providers who are thinking about entering an unserved market, but would become the monopolist and then be subject to rate regulation. And one thing that we found is that the FCC has already been quite successful at saying, “okay, we’re gonna give you a bunch of money to enter this market and be the monopolist, this market is unserved, here’s a bag of money to build a network in this unserved market. But because you’re taking this money, you have to be subject to our reasonable rates, reasonable service conditions.” And that has proved successful. People are willing to take that money subject to those conditions to offer service in those zones. And so I think what that suggests is that we need to continue to subsidize access in these expensive, unserved markets. But that doesn’t mean that we need to give up on ensuring that consumers don’t pay unreasonable rates, or receive unreasonable service.

[Joy] 33:34

I think that’s all of the questions I have. 

[Professor Narechania] 33:38

Okay!

[Yavuz] 33:40

It was such an interesting subject, thank you so much. You determined the problem and then you just showed us the solution that we need. So thank you so much for it. 

[Joy] 32:52

Yeah, for sure, thank you so much for your time. It was an exciting discussion about broadband access and affordability issues. So thank you, thank you so much for doing this with us. 

[Professor Narechania] 34:02

Thank you, I appreciate the chance to talk about the project with you. This was a lot of fun. Thank you. And check out the paper! 

[Eric] 34:38

Thank you for listening! The BTLJ Podcast is brought to you by Podcast Editors Isabel Jones and Eric Ahern. Our Executive Producers are BTLJ Senior Online Content Editors Katherine Wang and Al Malecha. BTLJ’s Editors-in-Chief are Jessica Li and Dylan Houle. If you enjoyed our podcast, please support us by subscribing and rating us on Apple Podcasts, Spotify, or wherever you listen to your podcasts. If you have any questions, comments, or suggestions, write us at btljpodcast@gmail.com.

The information presented here does not constitute legal advice. This podcast is intended for academic and entertainment purposes only.

Further reading and references:

Tejas N. Narechania, Convergence and a Case for Broadband Rate Regulation, Berkeley Tech. L. J. (forthcoming 2023). 

Telecommunications Act of 1996, Pub. LA. No. 104-104, 110 Stat.

Tejas N. Narechania, Convergence and a Case for Broadband Rate Regulation, Berkeley Tech. L. J. (forthcoming 2023). 

Home Owners’ Loan Act, 12 U.S.C. §§ 1461-1469 (1934).

See Leon Yin & Aaron Sankin, Journalists: Investigate Which Neighborhoods in Your City Are Offered the Worst internet Deals, The Markup, Oct. 19, 2022, https://themarkup.org/story-recipes/2022/10/19/journalists-investigate-which-neighborhoods-in-your-city-are-offered-the-worst-internet-deals. 

See Leon Yin & Aaron Sankin, Dollars to Megabits, You May Be Paying 400 Times As Much As Your Neighbor for Internet Service, The Markup, Oct. 19, 2022, https://themarkup.org/still-loading/2022/10/19/dollars-to-megabits-you-may-be-paying-400-times-as-much-as-your-neighbor-for-internet-service.