34 keep” system (“under which carriers split equally those costs that are solely incremental to interconnection, and recover all remaining costs from their own customers,” according to the report, id. at ii). Unlike the articles cited, it does address variations in quality of service, but only to argue that the ability of one provider to lower its quality doesn’t undermine the case for “bill and keep” because the quality-lowering provider will bear “the main impact itself.” Id. at 20. This is an interesting proposition, but, assuming its truth, it doesn’t connect in any obvious way to a flat ban on paid prioritization; if the Commission knows a way to make that connection, it hasn’t revealed it. The second, Gerald W. Brock, Telephone Pricing to Promote Universal Service and Economic Freedom, OPP Working Paper Series, No. 18 (1986), is an interesting consideration of the possible welfare losses that may follow from pricing that collects a high proportion of fixed costs from usage fees. As with the Atkinson & Barnekov paper, its connection to paid prioritization is unclear, and the Commission’s opinion writers have made no effort even to identify a connection, much less explain it. In discussing a possible anti-discrimination rule, the paper posits one under which a firm may adopt “any combination of two-part tariffs, volume discounts, and so forth but is required to offer the same set of prices to all customers.” Id. at 44. Although it isn’t clear that the paper gives an endorsement to such a rule, such an endorsement would not support the Commission’s ban on quality-of-service based differentials. I apologize for taking the reader through this parade of irrelevancies. But it is on these that the Commission has staked its claim to analytical support for the idea that paid prioritization poses a serious risk to broadband deployment.