Thanks to Jeff Hoel for providing the transcript for Episode 34 of the Community Broadband Bits podcast with Dewayne Hendricks reflecting on some history, the National Information Infrastructure. Listen to this episode here.
00:15:
Lisa Gonzalez: Hello, and welcome to the Community Broadband Bits Podcast, from the Institute for Local Self-Reliance. I’m Lisa Gonzalez.
In Episode 34, Christopher and Dewayne Hendricks travel back in time. Dewayne has been involved in the telecommunications industry longer than most, and goes over some history for us. Dwayne discusses a term many have never heard: the National Information Infrastructure. Dewayne and Christopher compare today’s fiber and wireless environment with past plans for community networks, and how those plans altered in just a few short years. Here are Chris and Dewayne.
00:46:
Chris Mitchell: Dewayne Hendricks is back with us on Community Broadband Bits, the CEO of Tetherless Access. And the guest who was the first to make a repeat is not the first to make a three-peat. So, welcome back, Dewayne.
00:58:
Dewayne Hendricks: Thanks, Chris. Thanks for having me back.
01:00:
Chris: I want to make sure people know that you can run into both Dewayne Hendricks and I at Freedom to Connect, in Washington, DC, coming up on March 4th and 5th. It’s a terrific event. Dewayne always provides incredible wireless access. So, if you want to get a sense of how good Wi-Fi should be, that’s reason enough to come by. Just Google “Freedom to Connect” and — or F2C — and you’ll find the details.
Dewayne, you had reached out to me after listening to the Bruce Kushnick interview that we had done, talking a little bit about the history of some telecommunications efforts. And noted that there were some really — there’s some really important other issues that we didn’t have a chance to talk about that we should discuss. So, tell me what those are.
01:49:
Dewayne: Well, I’m really glad you had Bruce on, and gave him the opportunity to talk about what he’s been up to for quite a number of years. A lot of people aren’t aware of his excellent work. So I’m glad that happened. But it spurred me to contact you via Twitter, and do a rant about a bunch of stuff in the historical record of that period that Bruce was zeroing in on.
02:16:
Chris: I think it was actually a 12-Tweet rant, which is the best I’ve ever seen. So, kudos.
02:22:
Dewayne: OK, thanks. So, what I want to do here is to talk about the historical record. And I want to start by asking you, have you ever heard of the terms, the “National Information Infrastructure” AND the “Unlicensed National Information Infrastructure”?
02:41:
Chris: You know, I have not. I’ve seen them occasionally, in print, in older filings, or history, as I’ve tried to get a better sense of what was being done in the ’90s. But it’s not a term that I’ve really come across in my work, you know, on a day-to-day basis.
02:59:
Dewayne: That’s what I suspected. So, I want to correct that, because I think it’s very important. Because a lot of things get forgotten, in the current parlance. Like things that happened five years ago. I mean, you sort of have to hire an archeologist to go discover them — you know, rediscover them. All right? It’s sort of bad. The institutional memory in government is terrible. Like at the FCC. OK? So what I want to do is go into that a little bit. And start by just taking — going — doing this little story about my past, in that —
When I was in high school, the famous science fiction writer Harlan Ellison came by to give a chat to the student body. And one of the things he brought up was that — because somebody asked him, well, how do you come up with your stories? I mean, you write all these wild things. And where do you get these ideas? And he says, well, you know, things aren’t — it’s very easy to do that. And he said, for instance, like, think about, you wake up one day, and you remember this event that occurred, but nobody else does. OK? You’re the only one. All right? How would you feel? I mean, he said, you could write a story I that. So, let me illustrate. And he says, how many of you here have heard of the holiday — the national holiday — “Sweetest Day”? S-w-e-e-t-e-s-t. Sweetest Day. OK? And hardly anybody had, in the audience. And there were about a thousand people there listening to him. And — but I had. You know? So — And then he says, well, this holiday is — was concocted by the candy industry, and started in 1921. And it’s been forgotten. It’s like, in your generation. My generation, we remember it, because it was basically promoted by the candy companies. OK? This is, like, this talk was in the early ’60s.
05:04:
Chris: Right. I was kind of — I was imagining that it turned into Valentine’s Day.
05:07:
Dewayne: No, it didn’t. And it’s still — if you go to Wikipedia, you’ll see that the candy companies are still promoting this day. It’s the third Saturday in October — is Sweetest Day.
05:18:
Chris: OK.
05:19:
Dewayne: All right. So, there you go. So, I thought about Bruce, and it’s like, everything that he talks about, he must feel like a character in that Harlan Ellison story — science fiction story. OK? Because all this data that he’s turned up about how the telcos didn’t do X, Y, and Z, that they promised to do is, like, nobody knows about. He’s like an archeologist going back into the past. The government — our government — at every level, has a very poor institutional memory. So when he goes back to Washington and talks about this stuff that happened in the ’90s, it’s like, you know, what are you talking about?
A more recent example is — there was this company called Metricom, that was in existence in the late ’90s. And they had a nationwide — well, regional — and a number of cities coverage — offering Internet. OK? Their network was called Ricochet. Well, San Francisco was one of the cities it covered. And Metricom went out of business in 2001. But they had wired the entire San Francisco area, including Marin County, Oakland — you know, all up and down the Bay Area, up to Santa Rosa, down to Los Gatos. Tremendous effort. Using Part 15 unlicensed.
06:42:
Chris: Why — what is “Part 15”? What does that mean? Is it just a signifier?
06:46:
Dewayne: It’s Part 15 of the FCC rules. OK?
06:50:
Chris: OK. So it’s just — it’s just a chron- — every time they make a new rule, they just increment it by one?
06:54:
Dewayne: No. No. The parts are assigned to certain kinds of services. And Part 15 is where unlicensed devices are.
07:02:
Chris: OK.
07:03:
Dewayne: And the unlicensed rules that Wi-Fi uses are known as Part 15.247 and Part 15.249.
07:11:
Chris: OK.
07:12:
Dewayne: OK? Towards, you know, like about 2008, OK — Metricom had been gone for seven years — I was in San Francisco, talking with people in city government, and I mentioned the Ricochet network, you know, to the IT people. And they looked at me like I had two heads. It’s like, what are you talking about? You know? And I said — And I explained — and it’s, like, well, you know, this covered the entire city. It was on all your light poles and stuff. Really?
So, you see what I mean?
07:43:
Chris: Absolutely. I think, ultimately, it’s amazing to me. The more I look back at electricity, and how it developed. They were wrestling with many of the same problems. And that’s not to say that telecommunications and wireless and fiber optics have all the same characteristics as electricity. But so many of the same problems were wrestled with then. And, to hear people talking about it today, you would think that this is a whole new problem, and that we had no sense — that we’d never wrestled with it in the past. So, you know, it’s frustrating, to some extent. You can’t assume it’s unintentional that there’s this lack of historical memory. It’s — there’s certain industries that want to guide policy in a certain way, and they want to make sure that no one’s sort of digging up in that history. And someone does, they’re immediately discredited. When you look at the way the Susan Crawford’s been attacked, you know, it’s, oh, she just wants to return us to the 1900s, and this and that. It’s just — you know, I want to pile on a little bit and say that it’s not just an accident of history that this happens.
08:48:
Dewayne: No, it’s not. It’s deliberate, in quite a few cases. OK? So, I think it’s very important to refresh people’s — today, about what the historical record was about. You know, to tell a story. What Bruce is doing, he’s become a storyteller. Unlike a storyteller, it’s not passive. He’s also aggressive, in that, like, his plan now to go after the ALEC initiative.
09:16:
Chris: Right. The organization that’s been instrumental in passing the laws in so many states for the benefit of the big cable and telephone companies.
09:23:
Dewayne: Right. OK. So, what I want to focus in on is that — I do things — I try to segment things into decades. So if you look at the significant thing that happened in telecom in the ’80s was the Part 15 Rules. OK?
09:40:
Chris: OK.
09:41:
Dewayne: That enabled Wi-Fi. All right? If you look at the ’90s — OK — Clinton — the election of ’92 brought Clinton and Gore into office. OK? They took office in January of ’93. And one of their first initiatives — Al was into the — you know, the whole Internet thing. But it wasn’t a public Internet at the time. That didn’t happen until ’95. But what Gore was instrumental in cooking up, as part of the Clinton administration, was this thing called the “National Information Infrastructure.” OK? It was the equivalent of the National Broadband Plan, that Genachowsi kicked off during Obama’s first term. But the National Broadband Plan is a pale shadow compared to the National Information Infrastructure. Think of — Listen how that phrase rolls off the tongue. National Information Infrastructure. OK? Well, they went — Gore — the Clinton Administration went to the telcos. And the stuff that Bruce described started at the start of the Clinton Administration. So I won’t go over all that. But there was a push with wireless, in that there needed to be a wireless component of the National Information Infrastructure. So, Apple Computer took point on this. And people aren’t aware of this history. But they spent millions of dollars on regulatory affairs, in DC, pushing this agenda. OK? And I sent you a copy of their petition for rulemaking that was submitted to the FCC in May of 1995. It’s a very important historical document. Because the National Information Infrastructure got a lot of press at the time, because the telcos were talking about pulling fiber to all the homes in the United States. Gore and Clinton were going out doing prep — photo ops — pulling Ethernet cable in schools and libraries. Now think about this. The President and the Vice President have got their shirtsleeves rolled up, and there in some schools pulling Ethernet cables through the ceilings. OK?
11:53:
Chris: Right. So, we were really more ambitious, in terms of making sure people were connected, in 1995 than we are today.
12:02:
Dewayne: Yes. We had a vision. In that this National Information Infrastructure included the concept of not just telco-owned and -operated networks but COMMUNITY networks. OK?
12:16:
Chris: Right. That’s actually a phrase that appears fairly early in the Apple filing that you sent me. And I was just amazed to see that.
12:24:
Dewayne: Yes. And that was an important part of the National Information Infrastructure. OK? So that petition for rulemaking gives you the vision. And it was a — it was a wonder. And when you look at that vision that took place during the Clinton Administration, and you look at the Obama Administration, it’s like — what happened? How did we go backwards? OK? So, let me fill in the blanks some more here.
So, I talked about this decade view. So, the significant thing of the ’90s was the National Information Infrastructure and the Unlicensed National Information Infrastructure. Then we had the decade of the 2000s, when the Bush Administration came in. And we basically went back in time. OK? All right? Nothing. All right? Then Obama came in, and we had Genachowski, and — well, I won’t even — let’s just leave that — everybody knows what’s going on with that. But let’s go back to the Clinton Administration. OK.
So let me outline this — talk some more about the National Information Infrastructure. The petition that Apple submitted was, as I said, quite visionary. And if you look at where Part 15 was at that time, Apple had started and got the FCC to enact a service called Data-PCS. In that they felt that there had to be a cleared band, that was not the ISM bands, that could be used for unlicensed devices — data devices. OK?
13:58:
Chris: Now, let’s take a step back for a second, and just — you know, we have this electromagnetic spectrum, that’s all around us. And the FCC is basically in charge of parceling that out within the Unites States for — they have a couple of different objectives. But the — up until this point, I mean, we’re mostly focused on things like radio broadcasts and communications of military, and television broadcasts, and that sort of things. Is that right?
14:26:
Dewayne: That’s right.
14:27:
Chris: And so we have a whole bunch of spectrum that’s still sort of un-parceled-out. And Apple’s coming up with some ideas of how one could parcel it out.
14:37:
Dewayne: Yes. Because what they had in their back pocket was Newton.
14:40:
Chris: Um hum.
14:41:
Dewayne: Newton hadn’t been announced yet, but they know that they need it. See, part of the Newton model was ad hoc networks.
14:48:
Chris: And Newton was sort of the iPhone, twenty years early.
14:51:
Dewayne: That’s right. OK? So they knew that, to make Newton successful, they had to deal with this problem — like, if you were going to — you needed wireless, and you needed ad hoc wireless, well, where was it going to — where were you going to get the spectrum for that?
15:06:
Chris: Right. And ad hoc just basically means that you have devices that can talk to each other without having to go through some sort of centralized system, right?
15:14:
Dewayne: Right. No APs. It’s like, basically, you go into a conference room, say, with a bunch of Newtons — people would carry Newtons — and they form an ad hoc peer-to-peer network.
15:23:
Chris: Um hum.
15:24:
Dewayne: Now, think about that. It’s like, that’s what Apple was talking about. And we still don’t have that today. I mean, there’s peer-to-peer extensions to Wi-Fi, but nobody uses them. We all [go] through access points.
15:37:
Chris: And this is where the critique of Bob Frankston comes in, right? Which is, for the most part, the companies that dominate this interest are worried about billing paths. And they want to make sure that everything goes through them, so they can charge you for it. If you can just talk to any other device around you, you don’t need them.
15:54:
Dewayne: Bingo! Exactly! OK? So now you get an idea of why this vision was very important, in that Apple was driving — you know, they had a new, innovative product they wanted to get out. And they were willing to spend millions of dollars. And this was before Jobs came back to the company — all this transpired.
16:14:
Chris: Right.
16:15:
Dewayne: I was involved — I had formed — cofounded — Tetherless Access in 1990, and — so I was involved in this push, in that I spent a lot of time at Apple, working with a guy called Jim Lovett, who was the one leading the charge on this wireless initiative, the regulatory part.
16:34:
Chris: Um hum.
16:35:
Dewayne: And he was a part of Apple’s Advanced Technology Group. And people don’t — I mean, millions of dollars. So, Apple was in Washington before a lot of people are aware. So they got this Data-PCS service, which is an extension to Part 15. And they were able to get 20 MHz — 10 for what are called asynchronous services, and then 10 for synchronous services.
So, the telcos got in there, and they wanted spectrum for circuit-switched kinds of wireless connections. And Apple — and others, like HP and IBM, wanted asynchronous services — data services. So they got 10 MHz allocated for each one. And the rules that got adopted were developed by the industry. And they were called a “spectrum etiquette.” So, the idea was, you had a clear band that, the rules were, the devices that used that spectrum had to use the spectrum etiquette. And everything else was like the regular unlicensed service that we know, in that nobody had more rights to any part of this spectrum access than anybody else.
So, 10 MHz wasn’t enough. And Apple knew where they were going — as did Sun and HP and others — and they wanted to be able to do video. And they wanted to be able to have enough spectrum to do, say, about 25 megabits.
18:03:
Chris: Um hum.
18:04:
Dewayne: So they immediately started the push for the Unlicensed National Information Infrastructure band. They identified some spectrum at 5 GHz — 300 MHz of it — and they asked the Commission to create a new Part 16 service, that would be like Part 15, except there wouldn’t be anybody else in this spectrum except Part 16 users. OK? So that you could design your devices so that they didn’t have to worry about any interference from any other kinds of devices.
So — And the other things they wanted was — they put forth this notion of “community networking.” In that the notion was — because part of the National Information Infrastructure was running fiber to schools, libraries, and government offices. OK? And that’s what the Vice President and the President were going around, you know, showcasing — hey, we’ve got to get the places wired up with Ethernet. OK? When the fiber comes. Because the telcos have promised to bring fiber to all these buildings. OK?
19:16:
Chris: Um hum.
19:16:
Dewayne: That was the National Information Infrastructure. OK? And then, the libraries and, um, schools — Think about it. What Apple did was, they said, look, you know, people — or, governments — place schools and libraries where the population is centered.
19:37:
Chris: Um hum.
19:37:
Dewayne: So, they’ve done a pretty good job as to placing these things that there is — so if you have essentially a wireless link that can go 15 kilometers, you can go from one school to another. OK? All right? So, what they wanted was some rules so that you could have point-to-point links that would allow you to essentially link up these schools, libraries, and government offices. And they would be the hubs for the community networks.
20:08:
Chris: Um hum.
20:09:
Dewayne: So, this thing — again, the commercial Internet didn’t start until ’95. So this was pretty much an infrastructure that was protocol-agnostic. OK? But if you think of it from a TCP-IP standpoint, what they were talking about was enabling independent, autonomous networks.
20:32:
Chris: Right.
20:32:
Dewayne: And so the Unlicensed NII were essentially going to enable you to, now, use 5 GHz — and they picked that band because the spectrum was available, but it also had the characteristics that they wanted — to enable this ad hoc community networking model. So, the idea was is that people in the communities could build networks from the ground up.
This — the thing about Apple was, they were really successful. They were able to get this Data-PCS service, from start to finish, in just a couple years. Which is, in Washington, amazing. If you look at it like some of the proceedings going now — like whitespaces, and how many years that’s taken. Apple submitted this petition in May of 1995. The report and order that essentially brought this service into existence was issued in January of 1997. Now, isn’t that amazing?
21:27:
Chris: Right. Yeah. I mean, it seems like someone was motivated to get it done.
21:31:
Dewayne: Right. OK? So, I mean — but the Clinton Administration was behind this. And that’s how it happened. OK? They kicked butt and took names. OK? And industry was behind this. OK? All the leading information companies. And it got done. And it shows you what can happen.
But, you see, the whole lobbyist organization, as we know it today, didn’t exist then.
21:56:
Chris: Right. They learned from that, right?
21:57:
Dewayne: Aha! Yes. You got it. Yes. OK? They learned from that. So, in the second term of the Clinton Administration, he got all tied up into the impeachment and all that stuff. And then the Telecom Act of ’96 came out. And that’s when the telcos started to take over. So, for the later part of the Clinton Administration, the NII was abandoned.
22:21:
Chris: So, just to get the chronology down, even though the Telecom Act passed. And then, even — it was after the Telecom Act passed that the FCC completed the order, but there’s still just the inertia of everything, right? And that’s what ended up slowing down.
22:37:
Dewayne: Yeah. Yeah. In that equipment manufacturers had to — it was like — what, you mean we’ve got 300 MHz of spectrum? What? You know? What are we going to do with it? And so, it took a number of years for Unlicensed NII devices to get developed. And then we were into the Bush Administration. And then, you know, they didn’t support the NII, of course. Because now the telcos were running the show.
23:05:
Chris: So what happened there then?
23:07:
Dewayne: Well, there were no advocates in the government anymore. And there weren’t any —
23:11:
Chris: Oh — I guess — I guess what I mean to say is, why did the government need to do anything else? Wasn’t it completed, more or less? They’ve parceled out the spectrum, …
23:22:
Dewayne: Well, what was missing was the fiber to the schools and the libraries and the government offices. OK?
23:28:
Chris: OK.
23:30:
Dewayne: All right? What Bruce talks about. OK? That was the missing piece. It was, like, Apple did their part. You know. And in record time, they got these new rules in place for this new service. OK? And if the government had kept their thumb on the telcos, then everything would have come together. But without the fiber, there was no — why build the wireless networks?
23:54:
Chris: Right. So, basically, you sort of have the chain of events breaking down then. Without fiber deep into the communities, there were no towers that could support the services. So the device manufacturers had no reason to manufacture devices that nobody could use if they bought them.
24:10:
Dewayne: Yup.
24:11:
Chris: And so, what happened to that band of spectrum?
24:14:
Dewayne: Well, it’s being used by Wi-Fi.
24:16:
Chris: Um hum.
24:16:
Dewayne: So, if you look at, again, that decade that started in 2000, that was the decade of Wi-Fi.
24:23:
Chris: But the Wi-Fi, mostly, started off on a different — I mean, the — Wi-Fi mostly didn’t use the 5 GHz, I thought, until later.
24:30:
Dewayne: That’s right. Until later. And it’s not really using it effectively now.
24:34:
Chris: And it still has the power limitations, doesn’t it? I mean, it can’t go the distance that was envisioned by Apple. Is that — am I right in that?
24:42:
Dewayne: It — you can use, like — with ubiquity, you can do point-to-point links that do far beyond what Apple envisioned.
24:49:
Chris: Oh. OK.
24:50:
Dewayne: So, I mean, we had the devices, now, to implement the original Unlicensed National Information Infrastructure plan.
24:58:
Chris: Um hum.
24:58:
Dewayne: But what’s lacking now is the vision. So, if you look at the National Broadband Plan, that the Obama Administration came out with, it’s about pipes, and the speed of the pipes. But it’s not about an architecture. A vision about, OK, we’re going to have this national thing. And there’s going to be a Telco part, and there’s going to be other parts. There’s municipal parts. Everybody can play.
25:21:
Chris: Right. It actually reminds me. When I read Reed Hundt’s book, so “You Say You Want a Revolution.” Right?
25:28:
Dewayne: Yeah.
25:28:
Chris: I read his book. And it was interesting, because it occurred to me — I got a better sense of what happened in the ’90s, where it seemed like the Clinton Administration won, in the sense that the Internet wasn’t just envisioned as a way of transmitting video from powerful people to consumers. Or from powerful corporations to consumers. And so, we sort of won, in that regard. But with regard to the National Information Infrastructure, it still continues to further this idea, as put forth by the Bush Administration, and now the Obama Administration, that, essentially, big companies should be the ones building the networks and figuring out how to use them. And the networks shouldn’t just be something that anyone can go out and experiment with, and build. And connect their neighbors, or, you know, those around them.
26:46:
Dewayne: Exactly. Exactly.
26:19:
Chris: So, I mean, in some sense, we didn’t really win, in the Clinton years, so much as they — you know, it’s like a temporary victory, in terms of the Internet being this idea of just anyone being able to innovate and connect. And, over a period of 15 years, the companies that sort of lost that early battle sort of circled back around, and they’ve captured pretty much everyone who’s in elected office to thinking the way they do.
26:41:
Dewayne: Exactly. They control the vision. So, what I’d like to do now — and your show’s going to help get this out — is, like, hey, let’s go back to that National Information Infrastructure, and the Unlicensed National Information Infrastructure, and bring those back. That’s a better model. And I think it would please Frankston. You know? [laughs]
27:02:
Chris: Yup.
27:03:
Dewayne: That’s a better way to go forward than the current National Broadband Plan.
27:08:
Chris: Right.
27:08:
Dewayne: The historical documents are there. And when people see those historical documents, and see what was being done back then, you know, they’ll get a better idea of how we got shafted.
27:20:
Chris: Right. And just how much potential there still is. Right? We haven’t lost our opportunity. We still have that opportunity, if we put our minds to it.
27:29:
Dewayne: Yes, we do. So — But we’ve got to get fiber — you know, we’ve got to get fiber out there, one way or another.
27:36:
Chris: Um hum.
27:36:
Dewayne: Because we’ve got the wireless spectrum. And we’ve got the devices. But without — you know, it’s got to be a hybrid network.
27:43:
Chris: Right. And it’s not just the technology. And I know that you know this. But just to make it clear. The — It’s not just a matter of getting Verizon’s fiber out there. It’s getting fiber out there that is able to encourage interconnection and innovation that’s not just being controlled by a corporation with a very narrow idea of how it should be used.
28:03:
Dewayne: Exactly. Remember Sweetest Day. And what Harlan Ellison said about how easy it is to concoct an interesting science fiction story. So, when somebody walks up to you and talks about an event that you’re not aware of, don’t brush him off. Look into it. There might be something there. Like the National Information Infrastructure.
28:26:
Chris: The more I’ve learned about how each community has solved their own problems, a lot of times, they’re inspired by people who tried to do something in the past and it didn’t work out.
28:34:
Dewayne: Yes.
28:34:
Chris: And so, all success comes from getting back up after you’ve fallen down.
28:41:
Dewayne: And maybe, when people dig back to that era, they’ll come away with a different idea about Apple and what it did.
28:50:
Chris: Yeah. It makes me a little less of an Apple hater, for myself. So, … [laughs]
28:55:
Dewayne: Well, yeah. I mean, really. I mean, before Jobs, there was an Apple. And it was doing a lot of amazing stuff. And I could do a whole show on that — about Newton and all the missed opportunities, the stuff Jobs canceled when he got back.
29:10:
Chris: Um hum. Well, it seems like it’s the continuing tension between Wozniak and Jobs. And the two of them were both incredibly visionary, in different ways. And I would love to see Wozniak’s visions being ones that we fulfill more, moving forward.
29:25:
Dewayne: Me, too.
29:26:
Chris: Well, thank you so much, again, Dewayne, for coming on, and bringing some history lessons, so we can have a better sense of where we’ve been. Which is always helpful in figuring out where we should go.
29:38:
Dewayne: My pleasure, Chris. ‘Til next time.
29:39:
Chris: Yes.
29:40:
Lisa: That was Christopher talking with Dewayne Hendricks, CEO of Tetherless Access. As Chris mentioned in the podcast, this was Dewayne’s third visit to Community Broadband Bits. If you haven’t already, you can hear more from Dewayne in Episodes 18 and 25. Be sure to check it out. We’re sure Dewayne will be back in the future. His wealth of experience in telecom always brings an enlightening conversation. If you have any questions or comments, please send us a note. E-mail us at [email protected] . And our handle on Twitter is @communitynets . This show was released on February 19th, 2013. Thanks again to the mojo monkeys for their music, licensed using Creative Commons. The song is called, “Bodacious.”
30:19:
This article is apart of MuniNetworks. The original piece can be found here
