Any extension of the #solar investment tax credit faces a tightening window

While some members of Congress have sponsored bills that would extend the investment tax credit for solar energy, that window for passage is closing.  One question is, if the investment tax credits were to expire, would investment in solar deployment be negatively impacted?

An online article in The Wall Street Journal presents two arguments on what impact the expiration of investment tax credits may have on solar investment and deployment.  On one hand, supporters of the tax credit, which amounts to 30% reduction in the basis of eligible property invested in, believe that employment in the industry would be reduced by approximately 80,000 jobs in 2017.  Solar installations for residential customers would fall by 94% in 2017 while utility-scale projects would evaporate completely.  Supporters also argue that if prices for installing solar were to fall in the absence of the investment tax credit, deployment of solar would suffer.

Opponents of extending the investment tax credit for solar believe such an action may actually stimulate more investment and residential ownership of solar panels.  Getting rid of the investment tax credit would have a small impact because incentives for developers and residential consumers were never that big to begin with.  Financial middlemen absorbed almost half of the investment incentives leaving developers and residential consumers with effectively 15% of the incentives.  It’s estimated that if they were a rise in prices as a result of eliminating the investment tax credit for solar, that increase would be approximately 2.5%.

In addition, opponents argue that getting rid of the credit opens the door to alternative methods of financing solar deployment.  The market may see securitizing solar leases as one way of raising capital necessary for continued investment.  Also, self-financing may show itself a less expensive option than leasing should the credit be eliminated, especially in light of the falling prices for solar panel installation.  Ir’s estimated that self-financing lowers installation costs for residential consumers by 23% while commercial customers may see a reduction of 87%.

Whether an extension is passed in time before the end of 2016 depends on how well Congress leverages the time remaining between now and when campaign season really gets cranking up.  Staffers on Capitol Hill see the best time for legislative action to take place in the first half of 2016.

At least two bills of interest to the solar industry have been introduced in Congress.  HR 2412, introduced by Congressman Mike Thompson, Democrat of California, on 19 May 2015, would extend investment tax credits for solar and other renewables to 1 January 2022.  HR 2412 has 39 co-sponsors.

Senator Brian Schatz, Democrat of Hawaii, introduced on 14 July 2015 S 1755, a bill that would give residential consumers a five-year extension on the investment tax credit.  S 1755 has six co-sponsors.

Republicans have in the past expressed support for the investment tax credit.  For example, House committee on energy and commerce chairman Fred Upton, Republican of Michigan, supported extension of the investment tax credit in 2008.

The Democrats that have taken the lead on these initiatives will have to ramp up their efforts in order to beat the 31 December 2016 expiration.

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.@TMobile’s zero rating plan shows how oppressive #netneutrality is

T-Mobile has announced a plan called “Binge On” that allows its subscribers to stream for free videos from certain content providers. According to the company’s website:

“Starting November 15th, Simple Choice users on a qualifying plan are FREE to stream unlimited video on your favorite services like Netflix, HBO NOW, Hulu, and many more without using a drop of your data. Nothing to configure – all automatically applied to your plan. Streamers, go ahead and Binge On™.”

This type of plan, known as “zero rating”, can be likened to dialing 1-800 to reach businesses of your choice.  The discount in pricing, if you will, comes from the subscriber not having the streaming count against their data plan.

Based on what I’ve read in The New York Times, proponents of net neutrality, the concept that calls for equal treatment of traffic from all providers, are up in arms about what they believe could amount to larger content providers like Netflix obtaining an advantage where T-Mobile subscribers decide to play in video streaming heaven by downloading movies and TV shows from the biggest driver of traffic in North America.

But while proponents warn of a possible tsunami of other wireless providers following suit, Wall Street didn’t appear too concerned about the plan as reflected in T-Mobile’s share performance since 10 November.

Should investors in the “Uncarrier” have anything to worry about from the Federal Communications Commission? It all depends on how they apply their net neutrality rules. According to 47 CFR 8.7:

“A person engaged in the provision of fixed broadband Internet access service, insofar as such person is so engaged, shall not unreasonably discriminate in transmitting lawful network traffic over a consumer’s broadband Internet access service. Reasonable network management shall not constitute unreasonable discrimination.”

47 CFR 8.11(d) defines reasonable network management as:

“A network management practice is reasonable if it is appropriate and tailored to achieving a legitimate network management purpose, taking into account the particular network architecture and technology of the broadband Internet access service.”

The Commission will be forced to apply 47 CFR 8.11(d) which from public administration 101 is always problematic and case-by-case.  The Commission will have to reconcile Chairman Tom Wheeler’s flowery rhetoric about virtuous cycle of innovation and democratizing voices on the Internet with the hard cold realities of business.  That reality is that the legitimate network management purpose of a carrier is to leverage its technology to generate the greatest amount of profit.  This is maximized when a carrier provides its subscribers with the best service.

T-Mobile should argue that it generates at this time the best customer value by providing a discount on access to the best content available and right now that includes Netflix and Hulu and a few others. T-Mobile is stopping its subscribers from accessing content of their choice. It is using the best content to retain current subscribers while trying to obtain new ones. Binge On is an appropriate profit generating strategy.

If the Commission is serious about AT&T and Verizon facing true competition, it will have to let the smaller players use innovative marketing to compete. The Commission shouldn’t speak out of both sides of its mouth.

Posted in broadbad, broadband access provider, Federal Communications Commission, net neutrality, regulation, smartphones, T-Mobile, Title II, wireless | Tagged , , | Leave a comment

To best understand the economy, replace government with self?

The Republican presidential debate on 10 November 2015 did little to enlighten me on how these candidates view the role of American government in the economy.

Ted Cruz, the senator from Texas, shared with us that he intended to eliminate four or five agencies along with a plan for reducing taxes.

Donald Trump, while reiterating the need for a physical wall between the United States and Mexico, also shared with the viewers his plan to cut taxes on the middle class while raising taxes on his wealthier friends.

Just about everyone had a tax plan that they argued would help put more money in the pockets of Americans while businesses, freed from onerous regulations, would be free to spend more on hiring American talent because they would have an incentive to stay in the United States and conduct business.  The rhetoric of tax reduction and reducing the size of government was not surprising last night and quite frankly had me bored by about the 75th minute of the debate.  So bored had I become that I even declared on my personal Facebook page that this debate would be the last political debate that I would ever watch.

Not that the moderators did a poor job. On the contrary, Gerald Seib, Neil Cavuto, and Maria Bartiromo did a very good job keeping the discussion on the economy and, to the relief of Ben Carson, were wise enough not to ask any questions requiring one to recall what they said in high school.

The poor performance was actually delivered by the candidates. None described America’s actual politico-economic system.  They all decided to fall back on the parlor trick of watering down a complex topic of the economy to one of taxes and jobs. Study economic history and you’ll see that the economy has never been just about taxes and, in my opinion, hs not much of anything about jobs.  Whether in Benin, Brazil, Cuba, Ghana, Russia, or the United States, the economy has always been about extarcting and managing resources.  For a nation-state’s economy, it has been specifically about the extraction and management of resources for the benefit of the elite few that lay ultimate claim to or try to exercise authority over resources.  It is the “who” or the “final benefit” that is always left out of the equation.

A discussion about jobs and taxes are nothing more than the red meat politicians throw at the electorate to get a vote.  Jobs and taxes are packaged as a narrative for sale to Joe Six-Pack with the hopes that Joe ascertains enough benefit from the offer. Joe has no idea as to the package’s true cost.  He doesn’t do enough homework because the cost of gathering the information is too much; too time consuming.  It’s easier for him to digest the job projections and go “yeah, yeah” when he hears he may get a 20% reduction in his taxes or get a rebate check of $300 so he can go out and buy a sofa.  Any gains to Joe would be as short term as the aggregate output gains to the nation-state.

Rather than buying into the politician’s definition of the economy, Joe Six-Pack should base a decision on what the economy is by simply looking at himself as an economic unit. To be a successful individual economic unit, Joe will have to first first ascertain his resources, his capital, not from the consumer-based view of a policy paradigm based on jobs and taxes, but from a producer-based paradigm based on having the resources necessary for sustaining myself. Do I have land, minerals, air, sources of energy upon which I can sustain myself? If not, where can I extract these resources? How best do I manage them so that I can sustain myself?

At this point you are probably saying, “Is this guy recommending we go back to the Dark Ages?” No, I’m not. However, the concept of self-reliance should never be abandoned especially if you believe that you are in the best position to make the best economic choices for yourself.

Today’s technology is providing the tools necessary for increased self-reliance.  As renewable energy technology improves, more Americans are opting for supplying their own energy needs. Making more unlicensed spectrum available means using more innovative devices at home that can enhance your productivity or your leisure. Technology can make transportation a resource versus the consumption of a final good. Why buy a car that sits most of the time idle when technology allows you to access transportation on demand?

As much as the Republicans talk about personal and economic freedom, their narrative on the economy boiled down to “this is what we can for you.”  We, government, can reform your taxes rather than freeing you from them. We, government, can create jobs rather than you creating your own commercial value and selling that value on an open market.

The GOP repeated the same mantra as the Democrats. We will continue to monopolize the resources you need to be self-sustaining while sending a little chump change your way.


Posted in economics, Economy, Election2016, employment, energy, libertarian, liberty, Political Economy, renewable energy, spectrum | Tagged , | 1 Comment

Some make argumement that the @FCC’s #spectrum proposed rule making doesn’t go far enough

I wouldn’t exactly say that a political battle is brewing per se around the Federal Communications Commission’s proposed rule making on opening spectrum use beyond 24 gigahertz but some interested parties would like to see the Commission open up this portion of the electromagnetic wave opened up to more technology than just mobile wireless.

For example, the Consumer Electronics Association wants the Commission not to focus solely on mobile broadband but on a wider range of services.  Harold Furchgott-Roth in a piece for Forbes argues that the Commission should allow for flexibility in spectrum use by not limiting the type of technology that can be developed and commercialized in the high frequency bands.  Like CEA, Mr. Furchgott-Roth believes just limiting the 24 GHz to 39 GHz to mobile broadband would be a waste of spectrum’s final frontier.

During the comment period on the Commission’s proposed rules we may get a better view as to how the private sector wants the spectrum real estate developed.  From an entrepreneurial and investor perspective, Mr. Furchgott-Roth and the CEA make good arguments.  Can the markets afford a restriction on innovation in the high-frequency space where the Commission for the most part limits use of this spectrum to mobile wireless?

Posted in broadband, capital, entrepreneur, Federal Communications Commission, Internet, spectrum | Tagged , | Leave a comment

.@FCC, #Obama Administration need a change in their political mindset on #capital

The politics of Washington is not commensurate with capital flow when it concerns broadband investment.  The Federal Communications Commission’s decision to apply Title II common carrier rules has resulted in a decrease in capital expenditures.

It has been reported that during the first half of 2015, AT&T saw a decrease in capital expenditures of 29% relative to 2014.  Charter Communications also saw a decline of 29% relative to 2014 while Cablevision saw capital expenditures fall off by 10% versus last year. CenturyLink was down nine percent while Verizon saw a fall in capex of four percent.

The politics pushing the FCC toward their anti-capital decision was driven by a grass roots group argument that freedom of expression was being challenged by the potential bottlenecks that broadband providers could create.  With narratives that included claims that consumers would not be able to create content on the internet or access the content of their choice, at least the three Democratic FCC members fell sway to it.

Edge providers, like Netflix, also played the “threat to democracy” card, arguing that broadband access providers , via paid prioritization, would discriminate among content providers and deny consumers access to their content.  Netflix, however, has been able to hedge its political bets by paying some of these broadband providers for fast lanes so that video traffic to its subscribers is not congested.

Now the political center of gravity lies in the Congress, at least this week, as the House committee on energy and commerce takes a look at how Title II common carrier treatment of broadband will impact investment.  Given Republican control of the committee, it’s no surprise that the committee’s leadership sees Title II as a burden on investment.  For example, the committee’s majority takes issue with the FCC’s finding that the total annual cost on all broadband providers for complying with the application of the FCC’s Title II rules would be approximately $700,000.  The majority believes the annual cost of compliance could be as much as $52 million.

Having supervised a tariff shop for a state regulator and drafting and filing tariffs as a staff attorney for a law firm, I can assure you that the cost of complying with Title II rules will well exceed the $6.95 per hour that the FCC estimates.  We are not talking flipping burgers here.

Politically, reversing the impact Title II regulation will have on broadband investment is out of the hands of Congress, at least in the short term.  Should a Republican win the White House in 2016 and the GOP maintain control of both chambers of Congress, then investors should expect a new FCC Republican majority to repeal the rules.

A repeal by the Republicans could be moot should the United States Court of Appeals-District of Columbia find that the rules have no statutory basis or that the FCC has not shown why its earlier treatment of broadband as an information service should be abandoned.

The probabilities of a court decision or an election outcome in favor of broadband providers is difficult to calculate but the likelihood of the FCC or the Obama administration changing its mindset about Title II’s impact on capital flows to broadband is definitely zero.  Both the President and the FCC’s three Democrats have invested too much political capital in steering the wrong course.

Posted in Barack Obama, broadband, capital, Internet, net neutrality | Tagged , , , , | Leave a comment

Bernie Sanders wasn’t the only non-capitalist on the stage last night

Last night when CNN’s Anderson Cooper asked who, besides Bernie Sanders, was not a capitalist, every hand, including Hillary Clinton’s, should have gone up.   None of the Democratic candidates have careers that would put them into the capitalist box.

Webster’s Dictionary defines a capitalist as “an owner of wealth used in business.”  A capitalist system or capitalism is where factors of production and distribution are privately held.  While the candidates may have their retirement and other savings in stocks, bonds, or a mutual fund, nothing in their bios indicate that they are a Rupert Murdoch or Warren Buffett.

Mr. Sanders, a U.S. senator from Vermont, has been a politician most of his adult life, having served as a mayor, congressman, and now a senator.

Martin O’Malley, former governor of Maryland, has also made politics his lifelong career, at least to this point, having served as mayor of Baltimore prior to winning the rights to reside in the Governor’s Mansion.

Lincoln Chafee is also in the near lifelong politician box and can also add author to his resume.

Jim Webb is also an author, known for writing about his Vietnam experience while serving as a U.S. Marine and extending his public service into a stint as secretary of defense and as a U.S. senator from Vermont.

Then there is Hillary Clinton.  While she and her husband, former president Bill Clinton, have accumulated some serious cheese since leaving the White House in 2001, Mrs. Clinton isn’t exactly the poster child for the robber barons.  Her and  her husband made their money the old fashioned way: speeches, books, and raising money for their foundation.

I guess they were afraid to have their progressive labels bundled with the word “communist” or “socialist.”  If they truly knew their positions on the economic philosophy totem pole, they would have realized that they are lumped in with the rest of us pee-ons.  The vast majority of citizens don’t own the factors of production and distribution so we can’t even call ourselves capitalists.  A significant number of Americans probably don’t know what the word means other than in the battle between good and evil, one does not want to be aligned with the communist hordes lurking in the likes of China, Cuba, or Russia.

But the candidates decided to play it safe.  Why let Anderson Cooper score big with the question.

Posted in Democrats, Economy, Election2016, Political Economy | Tagged , , , , , | Leave a comment

Congress shouldn’t fund a .@FCC that has misplaced priorities

Free Press has been calling on its constituents to encourage the Republican-controlled Congress to vote against a House appropriations bill that would significantly reduce funding for the Federal Communications Commission.  For Fiscal Year 2016, the FCC asked Congress for $388,000,000 in offsetting collections. This represents a $48 million increase over the FCC’s request for Fiscal Year 2015, which ends tonight at midnight.

House Republicans have been blatant about their unwillingness to fund the FCC’s net neutrality regime.  So serious are they about taking the wind out of the so called open internet that they have a budget bill that would provide the FCC with only $314,844,000 for Fiscal Year 2016.  If federal budgets represent national priorities, it is clear that net neutrality is not a priority for the GOP, whose members have railed against how onerous the rules are.

While the rules are burdensome, what is more telling is the FCC’s unwillingness to get out of the narrow vision box.  The FCC is still stuck on the concept of encouraging competitive telecommunications networks.  In the 21st century why would the FCC be concerned about a concept calling for a multiple number of firms providing point-to-point voice communications services via wire or wireline?

What the FCC should be concerned about is promoting the development of the information and data markets that are being created and transacted in over internet infrastructure.   Information and data are the currency being exchanged on digital networks.  Also the returns on stock that investors are seeing should be an indication as to where the economy via the internet is going.

According to data from Morningstar, the telecom services industry saw one-year returns on stock at 8.42%.  Three-year returns were 9.82% while five-year returns were at 9.64%.

In the information technology services industry, one-year returns amounted to 10.93%; three-year returns came in at 10.41%; and five-year returns were 12.16%.

The internet content and information industry saw first-year returns of 17.04%; three-year returns of 23.90%; and five-year returns on 18.70%.

I don’t pretend to be a stock analyst but if the FCC really wants to encourage competition on the internet, shouldn’t the agency promote entry into the higher performing industries?  If the FCC wants to convince me that they are interested in economic growth, their analysis should be based on the current reality of the internet economy and the data and information markets.

Posted in broadband, Congress, Internet, Republicans | Tagged , , | Leave a comment

.@FCC and hypothetical competition

Last week, Federal Communications Commission general counsel Jon Sallet delivered remarks to the Telecommunications Policy Research Conference where he described the circumstances behind three recently attempted broadband mergers.  The term, “competition”, raised its head during Mr. Sallet’s speech as he argued that in the case of two of the mergers, signaling disapproval of or outright disapproving the mergers the Commission believed negatively impacted consumer welfare.

Reading Mr. Sallet’s remarks it was clear that the Commission still prefers turn a blind eye to the changes everyone else is seeing in the industry; that broadband companies are becoming content delivery, media companies, data analytic companies, or a combination of the three.  Verizon’s purchase of online legacy media company AOL and AT&T’s purchase of DirecTV are two examples of convergence 2.0.

In addition, not only are AT&T and Verizon ready and able to use their wireless networks to deliver content for consumers and eyeballs for advertisers, they are collecting and selling to third-parties the data they collect on their access networks.  The data they sell to third-parties may be used to better define a subscriber’s user experience or to determine buying habits such that better, more targeted advertising can be created.  The openness of internet infrastructure architecture is such that other data analytics and data broker firms are competing with broadband providers to gather, collate, and sell this very same consumer information. This along with content, in my opinion, is the closest thing to competition involving internet players.

But what about a competitive market for consumer access services via broadband?  While the number of choices for networks that get you online may differ based on whether you are a rural, suburban, or urban dweller, it still remains that you have a choice involving more than one carrier.  Progressives often cite how much better European and Asian countries are doing in terms of subscribers per capita when analyzing the “dearth” of choice in the U.S.  Some will argue that a European style mandate that opens up the last mile to competitors may do the trick. What progressives consistently overlook is that the Commission’s authority to open up the last mile with a European-style mandate is dead on arrival because permission to deploy in the last mile depends on local or state authority.  Franchise agreements and certificates of public convenience and necessity are the biggest bottlenecks to the very competition progressives and the Commission continuously choose to ignore.

So, if consumers aren’t happy with the quality or quantity of broadband access choices, they may have to include in their residential decision matrix, along with good schools and tax schedules, the amount of broadband choice available in a locality.

The irony is that progressives may have further shot their broadband access competition argument in the foot by advocating for onerous net neutrality rules.  Even if state and local governments further loosened franchise restrictions for entering local markets, there are for now network management, transparency, no blocking, and no throttling rules that new entrants will have to comply with.  Net neutrality has raised another barrier to entry that may serve to dissuade the very competition its proponents allegedly want.

What Mr. Sallet left out of his remarks was any discussion on capital flow.  This is one of the downsides of too many lawyers and not enough economists at the Commission.  While broadband networks have benefited from many billions of dollars in investment, that investment is tapering off.

According to U.S. Telecom: The Broadband Association, broadband capital expenditures totaled $78 billion in 2014.  Since 1996, total broadband capex was $1.4 trillion. But, according to one member of the Commission, broadband capex is falling.  In remarks to the American Enterprise Institute, Commission member Ajit Pai noted that major wireless companies saw a decline in capex of 12% during the first half of 2015.

Compounding Commissioner Pai’s observation is another observation by former Commission member Harold Furchtgott-Roth.  Mr. Roth shared in a recent piece that annual growth rates in capital expenditures in the information sector, the sector most impacted by broadband spending, has been running below the national rate for capital expenditure. While capex in the information sector has been running at an annual rate of 8.2% between 2010 and 2013, the average for overall capex is 10.7%

Broadly speaking, the only competition that matters is competition for resources and capital. Onerous regulations with a negative impact on capital expenditure growth rates will make investors go the other way.

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Would more transparency on the part of data brokers be good for investors?

I came across an article in The Wall Street Journal about “device fingerprinting.” Device fingerprinting is information collected about a remote computing device for the purpose of identification. Data brokers use fingerprints can be used to fully or partially identify individual users or devices even when cookies are turned off.

Back in 2014, the Federal Trade Commission produced a report addressing the lack of transparency in the data broker industry.  While the report does not explicitly use the term device fingerprinting, the FTC does describe web crawling on particular websites containing public information and the use of application programming interface among the methods used to collect information.  Based on its description, device fingerprinting appears to take its place among these collection methods.

The FTC has recommended that Congress pass legislation that would provide consumers with access to the information data brokers collect on them.  It was also recommended in the report that consumers be allowed to opt out of a data brokers collection efforts. For further transparency, the FTC also recommended that a central website listing data brokers and describing their data collection policies be created.

In March 2015, Senator Ed Markey, Democrat of Massachusetts, introduced S. 668, the Data Broker Accountability and Transparency Act of 2015.  The thrust of the bill appears to focus on the accuracy of the data collected and shared; the transparency about why information is being collected; and the ability of the consumer to review the information collected and requesting that information not be used for the purposes collected.

It would be surprising to see the bill go beyond these three main restrictions.  Congress has shown over the past two decades a wariness about regulating commerce on the internet.  Regulating broadband, the on-ramp that gets the consumer to the information superhighway is one thing.  Regulating the actual commerce moving on that highway is a different story.

Ironically, it would especially put net neutrality advocates in a tight position between so called openness and privacy.  It is the open network architecture of the internet that allows for apps to capture information from websites and transmit the information to third-parties for packaging and analysis.  This is the openness that net neutrality types were advocating for. The millions of Americans who supported the open internet campaign may not like the result of net neutrality, that their privacy may have been put in some jeopardy.

S. 668 has been in committee for six months and shows little sign of moving to a vote much less the floor.  Since the language of the bill does not necessarily sound the death bells for the data broker industry, even if it passes and compliance costs increase, the increase in demand for data that the industry provides may offset these costs.

Posted in big data, broadband, data brokers | Tagged , , | Leave a comment

Pluralism, Capitalism, and .@RealBenCarson

Ben Carson has not demonstrated that he understands pluralism or that he can craft a political economy suitable for investors and the flow of capital to businesses or households.  For these reasons he should not be president of a political-economic-social jurisdiction whose economy is driven by a free market.

First, regarding pluralism.  Dr. Carson’s recent comments over the weekend, where he stated that he would not advocate the selection of a Muslim for leader of the United States and that the Muslim faith is not consistent with the Constitution, struck me as philosophical output of a person who does not understand that America is a pluralistic society.

As a pluralistic society, where there are a multitude of competing interests, a national leader cannot afford to brush aside one interest in favor of another.  He or she must find a way to balance these interests and find a way to reconcile them.  If not then that is where the democratic component of American society will kick in: that leader will find themselves out of office in the next election.

Dr. Carson appears to believe that, as president, pluralism means choose one interest and promote only that interest.   As the chief executive officer of American government, Dr. Carson won’t have that luxury.  For example, what happens when his Department of Justice is faced with the issue of whether a practitioner of Islam has been discriminated against in the workplace?  Would Dr. Carson’s apparent bias against Islam trump his duty under the law to protect the civil rights of all Americans?

What is also of interest is Dr. Carson’s flawed reading of the U.S. Constitution.  Article II, which describes the eligibility requirements for and the selection of the president, makes no mention of a religious test for the office.  How Dr. Carson draws the conclusion that Islam is out of step with the Constitution is a mystery.  Then again, maybe Dr. Carson is referring to his physical constitution; that the particular practice of Islamic faith is so foreign to him that it makes him throw up.  Even if that were the case, that is no reason for a blatant misread of the U.S. Constitution.

The divisiveness that Dr. Carson risks by advocating for a religious fringe is not good for the flow of capital in the United States.  As head of state, the President should set the tone that America will stick to its egalitarian creed; that this is a political economy that does its best to avoid social disruption that may result from antagonizing religious and other cultural sects.  The United States is not a third world or emerging market jurisdiction attempting to throw off the negative impacts of tribalism.  It is supposed to represent a forward thinking and moving society.  Dr. Carson needs to be reminded of this.

Posted in Election2016, GOP, Republicans | Tagged , , | 1 Comment