23 any firm deadlines to rule on [requests for advisory opinions] or issue response letters.” Id. ¶ 234. The palliative effect of these procedures may be considerable for the very large service providers. They are surely accustomed to having their lawyers suit up, research all the angles, participate in proceedings after notice has been given to all potentially adversely affected parties, and receive, after an indefinite stretch, a green light or a red one. For the smaller fry, the internet service provider firms whose growth is likely to depend on innovative business models (precisely the sort that seem likely to run afoul of the Commission’s broad prescriptions; see part II.B), the slow and costly advisory procedure will provide only a mild antidote to those prescriptions’ negative effect. This of course fits the general pattern of regulation’s being more burdensome for small firms than for large, as larger firms can spread regulation’s fixed costs over more units of output. See Nicole V. Crain & W. Mark Crain, The Impact of Regulatory Costs on Small Firms 7 (2010). And in evaluating the impact on investment in broadband, which the Commission assures us the Order will stimulate, quality is surely relevant as well as quantity. Further, given the breadth and vagueness of the standards, many of the acts for which firms are driven to seek advice will likely be rather picayune. As head of the Civil Aeronautics Board in its what proved to be its waning days, Alfred Kahn got a call in the middle of the night from an airline trying to find out whether its application to transport sheep from Virginia to England had been approved. “The matter was urgent, because the sheep were in heat!” Susan E. Dudley, Alfred Kahn, 1917-2010, Remembering the Father of Airline Deregulation, 34 REGULATION 8, 10 (2011). The internet we know wasn’t built by firms requesting bureaucratic approval for every move.