Surge pricing, dynamic pricing, variable pricing, all types of pricing

I work for a company that does dynamic pricing in the live entertainment market.

Varying or dynamic prices is a big subject in urbanist circles.  Here, for example, is Ezra Klein / Vox analogizing two promising pricing ideas in the urbanist world:

https://twitter.com/ezraklein/status/545657680942346240

To the extent that both Uber’s surge pricing and DC’s variable pricing for parking involve pricing, they are similar.  But as these ideas come more to the forefront, I’d love for folks to understand more about the nuances. Continue reading

Parking is a Drag, but the Drag isn’t Parking Many People

The city of Austin has initiated a corridor study of the Guadalupe Street Corridor from 18th to 29th, more commonly known as “The Drag.” I encourage you to fill out their survey. One of the questions I wanted answered about how we allocate space on the Drag is: how much mobility does the Guadalupe parking lane provide?  So I dragged my ever-patient friend Marcus to, well, the Drag, and we counted parking spaces. The short answer is to the question is: not much.

By our count, there are 70 parking spaces on the Drag.  To put this in context, there are 128 parking spaces on San Antonio St. between MLK and 26th St, and 26 parking spaces in a single McDonald’s parking lot. There are 70 parking spaces on the small surface parking lot on the southwest corner of 25th and Guadalupe and 218 parking spaces in the St. Austin’s parking lot at San Antonio and Guadalupe, which also houses 3 storefronts.  Let’s put that in table form:

Area Spaces
McDonald’s at MLK 26
The Drag 70
Surface Lot 70
San Antonio from 18th to 26th 128
St. Austin’s garage 218

The spots on this table–and most especially the on-street Drag parking–represent a tiny fraction of the parking in West Campus, or even the parking within a single block of the Drag. The University Coop owns a large garage on San Antonio and there is another commercial parking garage on San Antonio which dwarfs the St. Austin’s lot.  If every single on-street parking space on the Drag were eliminated but the St. Austin’s parking garage were cloned at 25th and Guadalupe, we would have a net 148 more parking spaces and 3 more storefronts, as well as a lot more room on the road to dedicate to travelers.

More importantly, the number of parking spaces is tiny compared to the potential alternative uses for this lane. The Drag is home to most of Austin’s most popular bus routes (1/3/5/640/801/803), and some less popular ones as well (19).  A single 803 bus can carry 78 passengers and a single 801 bus can carry 101 passengers. In an hour of traffic, many many multiples more people take the bus along the Drag (in either direction) than have their cars parked there.  There is so much more we could be doing with this space than provide one long surface parking lot.

Next regulatory steps for TNCs and ridesharing

City Council has passed a regulatory framework for Transportation Networking Companies like Uber / Lyft. (The “TNC” name comes from the idea that they are creating networks of drivers and passengers to match.)  A lot of the regulatons are nitty, gritty details of whose insurance applies in what situations, who conducts what background checks, etc.  But the basic framework is pretty straightforward: TNCs are mostly allowed to operate, as long as they follow some rules. In some ways, the rules that they have to operate with are far more liberal than the rules under which taxicabs operate.  This is true in small ways, such as slightly different insurance requirements, and in large ways, like the fact that taxi drivers and companies do not have the right to set their own prices.  (Taxis, of course, retain a right that TNCs don’t: picking up street hails.)  Now that the political hubbub of getting an initial ordinance has passed, I’m sure that reconciling these two frameworks and harmonizing the requirements will be some of the next regulatory discussions, especially the approach toward generating access for the mobility impaired.

However, I’m more interested in talking about what big changes could come next.  First up,

Carpools

Both Lyft and Uber have begun to operate true ride-sharing services. Uber’s is known as Uberpool and Lyft’s is known as Lyft Line.  With these services, you request a ride (giving you starting and ending destinations) and opt-in to the service. They attempt to match other riders who are taking similar trips, then pick you up in turn and drop you off in turn. If they cna’t match, they will simply dispatch a driver to take you alone. Because of the efficiencies of taking multiple passengers in the same vehicle, the passengers get a discount, the drivers and the TNC make extra money (2 passengers fares with 20% discounts still add up to much more than 1 fare at full price), and everybody else benefits by having fewer cars on the road.To my mind, this is pretty much exactly what we want to encourage. Although I argued that TNCs may reduce congestion by acting as an emergency outlet allowing households to remain car-free, this service has a much more direct effect on reducing congestion, by combining two or more rides into a single ride.

True to their Silicon Valley ethic, both launched these services with questionable legality in California and have since received letters from California regulators telling them they were violating the law. If we in Austin could get out in front of California and legalize carpooling in this form, we could become innovators in not only using TNCs to reduce drunk driving and help car-free households, but also in attempting to use them to lower transportation costs and reduce congestion.

Beyond

Commute Carpooling

My understanding of the Uber/Lyft platform today is that it’s built on the idea of a driver making themselves available and then picking up requests that are sent to them. They are free to reject requests, but rejecting too many may disqualify them from future work.  An obvious expansion of their services would be for a driver to log in, say where they are going, and then match them with drivers. At this point, the carsharing service moves from being a nifty, well-run vehicle-for-hire service to being an ad-hoc carpool service. A driver who needs to drive into downtown from Northwest can advertise his services and pick up 4 others making a similar trip. The advantage this would have over traditional carpooling is merely convenience and ease of access.  You don’t have to set up a standing carpool, communicate with all your regulars about whether they’ll be late, etc.  Instead, you rely on the network to match those who are driving with those who are riding. I don’t believe that any new regulations are needed for this, but there might need to be changes in the TNC’s model.

Van Service

Eventually, Lyft and Uber may begin butting up against new private, data-driven transit services like Bridj, and at that point, there will be many regulatory changes needed.  Currently, for example, there are limits on the number of passengers in a given cab.  But for commutes such as the weekly, weekend back-and-forth between West Campus and downtown, a private provider might be able to provide a better, more specialized service for these passengers by bridging the gap between cabs and buses.

Conclusion

TNCs are not some solve-all that will single-handedly answer “the transportation question” for the city of Austin, but I have high hopes that they will go on to be far more than just taxis by another name. Indeed, in the process, I hope that taxis will see a huge improvement too.

Living car-free or car-lite in Austin has gotten a lot easier

I’ve lived in Austin for about 8 years, all of that time car-free. When I first moved moved here, I was frankly crazy to do so. I did all sorts of things without a car: dragging mattresses from one apartment to another in West Campus, walking miles because buses weren’t running–or just because. My whole life was planned around living without a car. One reason I lived in coops was so I could choose chores that didn’t require a car. Once I had to do my own grocery shopping, I would regularly take my jumbo grocery cart 50 minutes on the #3 bus up to Costco north, filled it up with groceries (stuffing the rest in my backpack), then take the bus back. I had at least 3 friends with whom I had mutual relationships of calling up and asking each other to use CapMetro’s trip planner for them.

It was actually a fun life for a 20-something, like playing a video game on hard mode. My friends and I spent a lot of time coming up with creative ways to move ourselves and our stuff. Other people had stories of getting drunk and winding up with the police; we had stories of police officers picking us up from walking along 2222, because he just didn’t think we looked very safe.  (He was probably right.) But it was hard. One time, picking up something from Craigslist, I got off the bus in a part of town I didn’t know well, headed the wrong way down the Ben White Blvd frontage road in the 100-degree heat, and got seriously desperate with cars whizzing by at 50MPH and no pedestrian-friendly businesses to pop into before a friend figured out where I was over the phone and set me on the right path. Under the best of conditions, getting any errands done in the summer was exhausting. Calling up a taxi company to get to the hospital and being told that nobody is available for an hour is the kind of experience that makes you question your choices in life.

In part because of recent political debates (legalization of Uber/Lyft,  lowering parking requirements for small apartments and ADUs), I’ve been reflecting on these experiences. Today, I still live car-free but it is considerably less crazy than it used to be. In part, this is because I’m no longer silly enough to think it’s a good idea for me to gather up some friends and carry a chaise lounge through West Campus at 10PM. But in part, it’s because the city and the world is just much more friendly to living without a car today than it was just a few years ago.  Here’s my list of ways my life is easier without a car now than it used to be, in no particular order:

  • Smartphones make it much, much harder to get lost.  My flirtation with heat stroke along Ben White would never happen today: if I were confused, I’d simply check the map on my phone.
  • Smartphones make trip planning much more flexible.  I used to have “last bus” times memorized for a wide variety of buses to make sure I could get home on time–and still got stranded occasionally when I would forget that it was Sunday. Today, I can easily just ask Google Maps or the CapMetro app to figure out the best way for me to take a bus home.
  • Sidewalks are getting more widespread and larger throughout the city, especially in the places I walk most.  Last month the city added a sidewalk in front of Vince Young grill, and a bike lane on 3rd Street.  Along my daily commute, at least a couple patches of missing sidewalk have been filled in that used to force me to cross a street or share a lane with cars–not very safe on foot!
  • Grocery delivery is a million times better.  Between Burpy, Instacart, and Amazon subscriptions, 90%+ of my groceries are delivered.  What would have taken me 3+ hours, heavy lifting, dangerous walking along pedestrian-hostile stroads with 80 lbs of grocery in tow is now done with a button click online.
  • Prepared food delivery is much easier.  Between GrubHub and Favor, pretty much anything can be delivered.
  • Density has brought more local food retail. In the two most recent neighborhoods I have lived in (West Campus and downtown), there has been a big jump in residential and commercial density. There’s a far broader quantity and variety of stores within walking distance of me, whether it’s convenience stores like Royal Blue or the dozen corner stores in West Campus, or tons of restaurants.
  • The food truck revolution. Not only is there more brick-and-mortar, but there are multiple food truck courts within walking distance of me, bringing even more variety of food. It used to be that buildingless parcels would be worse-than-useless to a pedestrian, filled in as surface parking lots. Now, many of those parking lots are being filled with very useful, tasty food.
  • Bcycle has only been in Austin for a few months, but you already see them everywhere. I’m not super confident enough on a bike to make this my main form of commuting, but they’re very convenient when I need them.
  • Uber / Lyft.  Uber and Lyft have been operating for the last few months. Most of my life doesn’t require a car, but since Uber and Lyft have started up, I am far more confident that if I suddenly needed a ride, I could find one.

Obviously, some items on this list are downtown- and campus-centric. People living in lower density places are unlikely to see a wide variety of stores within walking distance of them, for example.  I have the luck of a good job within a 1.5-mile walk of my home. For many people in Austin, it would be, well, crazy for them to live without a car. But these changes are real and more and more people will find that living car-free or car-lite is a good choice for them.

Playing around with a gridded transit system

Yesterday, I was exposed to a new tool that came out of Code For America: TransitMix.  It’s intended as a tool for allowing lay people (and eventually professionals) to draw up transit systems.   The map that I drew up (ideas you like are from Brad Absalom; ideas you dislike are from me)is a very preliminary interpretation of how ideas gleaned from reading posts on Jarrett Walker’s blog about a grid-based, transfer-happy system could work in Austin.  For this post, I will call the system I drew up Reimagined in the spirit of Houston’s System Reimagining (on which Walker consulted). For speed, I didn’t take on MetroExpress (i.e. 983, 985, 990), the Flyers (e.g. 103, 142, 171), or the UT Shuttles (e.g. FA, WC, LA).  I also ignored off-peak times for the same reason.

I constrained myself to reality in a few major ways: 1) using the same number of peak-hour buses that I calculated Cap Metro to use within MetroBus / MetroRapid (136 buses).  This gives a rough idea that the new system has similar total expected costs.  2) I attempted to keep coverage for as many locations currently served by a bus as I could, 3) I did my best to give average run speeds based on real Capital Metro runtimes along segments, including rest times for driver breaks.

I only drew this up for Devil’s Advocate purposes at this time–I’m intrigued by it enough to throw a Saturday afternoon into making it, but I’m sure there are issues I haven’t thought about.  It’s a very first cut, just an attempt to follow the principles and see where it leads.

Continue reading

Should we ban part-time taxi drivers?

Lyft and Uber have (re-)arrived in Austin, offering free rides for a couple of weeks, despite the City of Austin declaring they are operating against the law.  You can’t beat free, so I’ve been taking a lot of these rides.  All of my drivers have been part-timers, looking to supplement income.  This is in stark contrast to taxicab drivers, who are pretty much all working more-than-full-time hours.

The economic reasons why taxi drivers are full time make a lot of sense. Cabs are dedicated-purpose vehicles, going for the most part unused when they aren’t working.  Taxi licenses are an extremely scarce resource due to city regulations.   The taxi industry will find a structure to make sure these two expensive resources are working as often as possible.  Taxi licenses are issued to individuals, though; so this means that any structure that ensures that we have a lot of usage of our limited taxi licenses also ensures that our taxi drivers are working overtime.  The form this takes in Austin is high costs for either purchasing or leasing a taxi and high “terminal fees” for getting the right to use the taxi companies’ dispatch system.  Every month, each taxi driver starts deep in the hole and has to work a lot of hours just to break even, to pay for the fixed costs of their cab and their terminal fee.

So how do Uber and Lyft turn this dynamic around and allow for part-time drivers?  Uber and Lyft (whatever the legalities of their operations) are not limiting themselves to a city-capped pool of taxi licenses, nor are they limiting themselves to cars that are used exclusively as taxis. If a driver decides not to work Uber for an afternoon, a week, or a month, this doesn’t take the expensive fixed cost of a taxi out of their network, nor does it take the scarce resource of a taxi license out of their network.  Because of this, Uber and Lyft can do away with the terminal fee and instead just take a percentage of each ride as a dispatch fee.  Felix Salmon does the math and finds that, if the numbers are to be trusted, a full-time driver with Uber makes pretty good money compared to most taxi drivers, but a part-time driver does very well indeed.

There are many, many issues at play with Uber and Lyft, but from a very zoomed-out perspective, current city regulations make it uneconomical to have part-time drivers, and Uber and Lyft have come up with a model to change that.  Now, why we do we care?  Because taxis have very variable demand.  At peak hours, the number of licenses Austin hands out aren’t nearly enough to keep up with the demand.  But because drivers are starting off so far in the hole, they can’t just work peak hours; they have to work additional hours even if they’re very poorly paid for those hours, because they have to pay off the high fixed costs. So our current structure works for neither drivers nor riders: drivers have to scramble for every last ride in off-peak, but there still aren’t enough of them to give rides on-peak.  A structure (whether Uber/Lyft or something else) that allows drivers to come online during peak but doesn’t force them to work tons of off-peak hours could be beneficial to drivers and riders alike.  This presents a test of sort for any change in regulations.  Will it allow the economics to work for part-time drivers?  If not, then it really hasn’t accomplished much.

A new slogan: abundant housing

AURA, the urbanist group in Austin I’ve been so excited about, has adopted the language of “abundant housing.” The concept is simple: build enough housing for everybody who needs a home. Although abundance and affordability are intimately linked, the call for enough homes for everyone doesn’t require invoking affordability. It’s a strong statement of inclusivity and social justice on its own.

Abundant housing makes all housing more affordable

Even if you don’t buy my argument (and overwhelming consensus among economists, real estate people, etc.) that abundant housing leads to affordable housing, you should stand up for abundant housing because everybody deserves a home.  But I’ll flesh out the link anyway. I’ve compared the housing market to a game of musical chairs. If you don’t have enough chairs to go around, the competition is going to be intense not just for the last few chairs, but for every chair. Similarly, if there aren’t enough homes to go around, the competition for homes will be intense up and down the market. This is the situation today in Austin and in cities throughout the country: rising prices, cash-only sales, homes selling sight-unseen. The competition for homes is intense at all levels; even those who can definitely afford some housing are forced to contend with rising rents. Abundant housing aims both to make sure those at the bottom have a place to live and everybody else isn’t subjected to the intense competition that makes our current housing markets so hard.

Targeted affordability isn’t enough

Affordable housing can refer to mandated Affordability or housing that’s just affordable. Whether the specifics of the affordable housing strategy are bond-driven Affordable Housing, Affordable Housing setasides in new development, or targeted relaxation of laws that only allow new housing that will likely be affordable (e.g. very small units), these strategies are all based around the idea that the best way to improve affordability is to create new housing that will enter the market at the lowest end. In its worst form, you see not only a preference for housing targeted at the cheapest end of the housing market, but opposition to the creation of net new housing because that new housing is at the higher end.

But in a game of musical chairs, the intense competition for chairs doesn’t come from the fact that there are too many thrones and not enough folding chairs; it comes from the fact that there aren’t enough chairs, period. If there are ten fewer chairs than there are contestants, whether you add ten thrones or ten folding chairs, everybody will now have a seat. In this view, discouraging people from adding seats because they aren’t targeted at the particular folks who lost last round is perverse; you are hurting those folks’ chances of finding a seat, not helping them. Abundant housing is built around the same idea: policy that allows new housing to be created easily will allow more homes to enter the market, enough that everybody can find a place to live. With the competition between buyers/renters being less intense, rents won’t rise as much across the market. Whether that’s done through small new units cheap enough to hit the middle-to-bottom of the market, bond-supported Affordable Housing units, or new luxury condos absorbing the demand from the richest, there will be housing for all.

Lack of abundant housing overwhelms Affordable Housing

Affordable Housing policy is necessary to help those who need it, even when there’s enough housing to go around. For the musical chairs analogy, in a game with as many chairs as contestants, an adult might find themselves next to vacant chairs designed for children; a contestant with a mobility impairment might not be able to reach a vacant chair because the path is blocked. This is analogous to a well-functioning housing market in which there are still some folks who need a hand, perhaps temporarily because some bad thing happened or they simply lack funds; perhaps permanently if they have a reason they will never be able to make rent. But these intervention strategies are overwhelmed when there are simply too few chairs to accommodate all contestants. If there are fewer chairs than contestants, no amount of targeted interventions will help. They merely result in a different set of folks going without a chair. But fixing the abundance problem, the Affordable Housing efforts can go back to serving specifically those who need it even when there are enough chairs to go around.

Another positive development (accessory units)

Following up on the positive development of Chris Riley and Bill Spelman pushing to lower parking and density requirements for small units along dense corridors, Riley is back at it, this time teaming up with Mike Martinez to lower parking and driveway requirements for accessory dwelling units (secondary structures in the backyard of single-family homes).  Chris Bradford and Steven Yarak have great rundowns on why the ordinance is needed so badly and how it could be even better if it applied to more ADUs.

Chris and Steven can give you a better overview than I can of why ADUs are needed and why parking and driveway requirements make it so hard to build.  So I’ll add a perspective that is so obvious it shouldn’t need to be stated, but now and again we do well to repeat: parking and driveway requirements are unfair, backwards, and detrimental all around.

I live in Austin without a car.  At many apartments I’ve lived in, a solid chunk of the land was (un)used for the worst possible thing: an empty parking space, reserved for the car I don’t have.  That land could’ve been a garden absorbing rainfall and preventing runoff; it could’ve been an outdoor patio, providing me and the other residents with a place to enjoy the weather; it could’ve been more housing, allowing for me to split the costs of housing with another resident or roommate.  Is it useful or fair to require every resident of Austin that doesn’t have a car to still pay the costs of maintaining an empty parking space (and often driveway) next to their home?  Is it beneficial to the city or the planet to encourage residents to drive, over using choices like riding public transit or bikes?  (Crib sheet: answers are no and no.)

Even if I did have a car, though, requiring a reserved parking space for my home still wouldn’t make sense.  I lived in each case on streets with a significant share of their street space reserved for the sole purpose of parking automobiles. The city goes to almost incalculable expense to reserve space along almost every street for no purpose other than parking cars; yet frequently that space goes unused.  It is as if the city spent billions of dollars establishing swimming pools throughout every neighborhood, only to mandate that most private homes have swimming pools to ensure that the public swimming pools didn’t get overused.  Except, subsidizing swimming to that extent, while not a great use of funds, might at least be good for the health and enjoyment of the city, while subsidizing parking encourages emissions and traffic.

Likely, some of those who oppose the reduction in parking and driveway requirements don’t really want the parking requirements specifically; they just know that without them, there would be more ADUs, and they oppose that.  To the extent that this is true, it is a real shame.  The city requires a ton more parking spaces, driving up costs, harming the environment, and subsidizing traffic, all because some who couldn’t get the political forces necessary to achieve their (bad) objective of banning ADUs found a way of doing it by making it practically banned instead of actually banned.

I’m far from the only, first, or best person to make these points about parking.  If you’re interested in learning more, I suggest checking out Graphing Parking, a blog by Austin’s own Seth Goodman; Reinventing Parking, the internationally-themed group blog he participates in, and the canonical work, The High Cost of Free Parking, by UCLA professor Donald Shoup.

My email regarding Uber / Lyft / Sidecar, etc.

Mayor, Mayor Pro Tem, and Council Members–

I urge you to vote yes on resolutions 24, 25, and 26 regarding transportation networking companies. For people like me who do not drive, paid rides are an essential emergency backup. However, I have had so many bad experiences with taxi companies telling me they do not have enough capacity to give me a timely ride that I cannot consider them a reliable backup.

I use taxis when I am too tired, too sick, or carrying too much to walk or use public transportation. I have used taxis to take friends home from the hospital, to take pets to the vet (not allowed on Cap Metro buses), and to take myself to doctors’ appointments that weren’t on transit routes. I have been told that I will have a long wait because most drivers don’t want to work off-peak and that I will have a long wait because it was peak hours and most drivers were already occupied. Waiting for a long time for a ride to a hospital is the sort of defining experience that makes many people give up on living without a car.

Living in Austin without a car is difficult enough. Making it easier to sell rides will give more security to those of us who cannot drive to know that when we really need it, there will be a timely ride for us.

Let’s not make a deal

If you hang around the Austin (and presumably other city’s) zoning codes long enough, you get used to deals.  I’m not talking about compromises, where one side wants a height limit of 40′, the other a height limit of 100′, and they settle for 60′.  I’m talking about requirements built into code that a landowner can get out of if they satisfy some other requirement.  This principle is built so deeply into code, in fact, that it’s almost impossible to avoid.

The Vertical Mixed Use (VMU) zoning overlay allows a landowner to choose between the “base zoning” of a district or VMU zoning.  VMU zoning significantly reduces some limitations (FAR, density, see the linked Austin Contrarian post for definitions and details), and replaces them with different requirements: detailed specifications on acceptable building designs and requirements for some units to be designated as Affordable Housing (see link for definition of Affordable Housing).  Similarly, the University Neighborhood Overlay (UNO) allows landowners to build significantly more on a single property than they would be allowed under base zoning, but only if they agree to an extraordinarily detailed specification for how their building might look like.  (I continue to be amazed that these specifications forbid developers from developing new buildings that look historical because this “results in the devaluation of the real thing.”)  Transit-Oriented Development overlays work similarly; allowing greater densities in certain locations, as long as you follow certain design specifications.  The Downtown Density Bonus allows greater heights in exchange for funding Affordable Housing.  At a smaller scale, there are deals that allow developers to opt out of minimum parking regulations in exchange for providing bike lockers or providing parking for shared car services (e.g. Car2Go, Zipcar).

In general, I find myself in favor of each of these deals. VMU, UNO, and the DDB all provide an opportunity for a development that’s more of a proper scale for the locations of the building along major thoroughfares, or near UT or downtown. I don’t always think what the buildings are required to do in exchange is for the best, but it’s worth it to have that option.  Similarly, I’m in favor of vastly lower minimum parking regulations; if buildings provide bike lockers or Car2Go spaces, more to the better.

But for the short-term upside, there’s also a long-term downside: if either side of the deal changes, the whole deal will need to be renegotiated, making it much harder to make any changes.  When Council Members Chris Riley, Bill Spelman, and Mayor Pro Tem Sheryl Cole introduced an ordinance to explore the possibility of lowering minimum parking and density requirements for microunits along VMU corridors, the major objection expressed at Council was not toward the idea of allowing greater density or less parking itself, but rather that it would gut the existing VMU deal of less parking in exchange for more Affordable Housing.  (Again, see link for definition of Affordable Housing.)  Lowering minimum parking regulations citywide would have an effect on existing deals involving VMU, TOD, bike lockers, car2go, and thousands of ad hoc deals in which landowners agree to waive some development rights in exchange for reduced parking requirements.  It would be a nightmarish negotiation.  Each deal creates an opportunity for lowering the minimum parking needed in one situation, but also creates a constituency opposed to a broad-based reduction.

I’m not sure how to handle this situation–most new deals that come up are tempting, as they offer greater flexibility to build something of a more appropriate density than base zoning allows.  Some of them (VMU, UNO, DDB) have positively transformed the city, allowing far more people to find homes.  Yet, I fear that the more layers of deals that get added, the more difficult it will be to unravel. Small decisions like lowering minimum parking regulations even 10% will be impossible to make because of the number of stakeholders involved in the negotiations.

Fortunately, I feel very excited that this was one of the primary diagnoses CodeNext made [large PDF] in their review of Austin’s current Land Development Code: base zoning districts are ineffective, leading to complicated layers of opt-in, opt-out regulations.  I hope that a good solution can come up with to unravel these deals and that any future deals are made with caution.  A well-meaning deal that advances two priorities in the short-term can lead to paralysis in the long-term.