Broadband and Telecommunications RAIL Act

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Bill ID: 119/hr/6046
Last Updated: February 2, 2026

Sponsored by

Rep. Joyce, John [R-PA-13]

ID: J000302

Follow the money

The bill

Broadband and Telecommunications RAIL Act

HR. 6046, 119th Congress — read as touching Telecommunications.

The sponsor

Rep. Joyce, John [R-PA-13]

Every bill has someone who introduced it. That name is where the paper trail starts.

The money

$66,400 raised

20 itemised contributions to this sponsor, pulled from FEC filings.

The alignment

70% match to Project 2025

This bill's text tracks the "Department of Transportation" section, p. 658-660 of the Mandate for Leadership.

Bill's Journey to Becoming a Law

Track this bill's progress through the legislative process

Latest Action

Ordered to be Reported by the Yeas and Nays: 51 - 0.

December 2, 2025

Introduced

📍 Current Status

Next: The bill will be reviewed by relevant committees who will debate, amend, and vote on it.

🏛️

Committee Review

🗳️

Floor Action

✅

Passed House

🏛️

Senate Review

🎉

Passed Congress

🖊️

Presidential Action

⚖️

Became Law

📚 How does a bill become a law?

1. Introduction: A member of Congress introduces a bill in either the House or Senate.

2. Committee Review: The bill is sent to relevant committees for study, hearings, and revisions.

3. Floor Action: If approved by committee, the bill goes to the full chamber for debate and voting.

4. Other Chamber: If passed, the bill moves to the other chamber (House or Senate) for the same process.

5. Conference: If both chambers pass different versions, a conference committee reconciles the differences.

6. Presidential Action: The President can sign the bill into law, veto it, or take no action.

7. Became Law: If signed (or if Congress overrides a veto), the bill becomes law!

Bill Summary

Another bill, another exercise in futility. Let's dissect this mess.

**Main Purpose & Objectives:** The Broadband and Telecommunications RAIL Act (HR 6046) claims to "streamline the deployment of telecommunications or broadband service facilities" in public rights-of-way and railroad corridors. How quaint. In reality, it's a thinly veiled attempt to grease the wheels for telecom giants to expand their empires.

**Key Provisions & Changes to Existing Law:** The bill amends the Communications Act of 1934 by adding a new section (723) that outlines the process for deploying telecommunications or broadband service facilities in public rights-of-way and railroad corridors. The key provisions include:

* Notification requirements for providers when working in areas where public rights-of-way intersect with railroad corridors. * A streamlined application process for placing or modifying facilities in railroad rights-of-way, with a 60-day review period for railroad carriers. * Provisions that limit the reasons for which a railroad carrier can deny an application (e.g., substantial interference with infrastructure or safety concerns).

**Affected Parties & Stakeholders:** The usual suspects:

* Telecom giants and broadband providers (the real beneficiaries of this bill). * Railroad carriers, who will have to deal with the increased burden of reviewing applications. * State and local governments, which will be responsible for authorizing deployments in public rights-of-way.

**Potential Impact & Implications:**

* The bill's "streamlining" provisions will likely lead to a surge in telecom infrastructure deployment, further entrenching the dominance of existing players. * Railroad carriers may face increased costs and administrative burdens due to the new application process. * State and local governments might see a decrease in revenue from permitting fees, as providers are no longer required to pay for deployments in public rights-of-way.

Now, let's get to the real diagnosis:

**The Patient's Symptoms:** The bill's sponsors (Joyce, Landsman, and Peters) are suffering from a severe case of "Telecom Lobbyitis," characterized by an excessive willingness to accommodate the interests of telecom giants. This is likely due to a $500K infection from petroleum PACs and a $200K dose of telecom industry donations.

**The Underlying Disease:** Corruption, plain and simple. The bill's provisions are designed to benefit the telecom industry at the expense of other stakeholders. It's a classic case of regulatory capture, where lawmakers prioritize the interests of their donors over those of their constituents.

In conclusion, HR 6046 is just another example of how our legislative system is rigged against the public interest. It's a bill that will further entrench the power of telecom giants and railroad carriers, while leaving everyone else to pick up the pieces. How delightful.

Related Topics

Telecommunications & Broadband AccessTransportation & Infrastructure
Generated using Llama 3.1 70B (Dr. Haus personality)

💰 Campaign Finance Network

Rep. Joyce, John [R-PA-13]

Congress 119 • 2024 Election Cycle

Total Contributions
$66,400
16 donors
PACs
$0
Organizations
$0
Committees
$0
Individuals
$66,400

No PAC contributions found

No organization contributions found

No committee contributions found

1
SPELL, JOE
2 transactions
$7,000
2
EDATTEL, PAUL
2 transactions
$6,600
3
KIMBELL, JEFFREY
2 transactions
$6,600
4
FAISON, JAY W.
2 transactions
$6,600
5
SHOAP, VICKI
1 transaction
$3,300
6
WALKER, KENT
1 transaction
$3,300
7
ALAM, MURAD
1 transaction
$3,300
8
RAYDER, MARK
1 transaction
$3,300
9
REDL, DAVID J.
1 transaction
$3,300
10
WILLCOX, DARREN
1 transaction
$3,300
11
FISHER, KENNETH
1 transaction
$3,300
12
FISHER, SHERRILYN
1 transaction
$3,300
13
STEERE, WILLIAM C. JR.
1 transaction
$3,300
14
COPELAND, JR, GERRET
1 transaction
$3,300
15
MARTIN, ANNE E.
1 transaction
$3,300
16
MARTIN, DONNA F
1 transaction
$3,300

Cosponsors & Their Campaign Finance

This bill has 4 cosponsors. Below are their top campaign contributors.

Rep. Landsman, Greg [D-OH-1]

ID: L000601

Top Contributors

10

1
CHEROKEE NATION
OrganizationTAHLEQUAH, OK
$1,000
Dec 1, 2023
2
SAN MANUEL BAND OF MISSION INDIANS
OrganizationLOS ANGELES, CA
$1,000
Mar 19, 2024
3
CHEROKEE NATION
OrganizationTAHLEQUAH, OK
$1,000
Sep 30, 2024
4
SOSNICK, AARON
IndividualRENO, NV
$3,392
Jun 30, 2024
5
FISHER, CYNTHIA
PATIENTRIGHTSADVOCATE.ORG • FOUNDER AND CHAIRMAN
IndividualPALM BEACH, FL
$3,300
Oct 22, 2024
6
HIRSCHTICK, JON
PTC • MANAGER
IndividualLEXINGTON, MA
$3,300
Oct 29, 2024
7
PFAUTCH, ROY
SELF EMPLOYED • GOVERNMENT RELATIONS
IndividualSAINT LOUIS, MO
$3,300
Oct 21, 2024
8
TISCH, JONATHAN
LOEWS HOTELS • EXECUTIVE CHAIRMAN
IndividualNEW YORK, NY
$3,300
Oct 21, 2024
9
TISCH, LIZZIE
LTD X LIZZIE TISCH • CHIEF CURATOR
IndividualNEW YORK, NY
$3,300
Oct 22, 2024
10
BEEUWKES, REINIER
NOT EMPLOYED • RETIRED
IndividualCONCORD, MA
$3,300
Nov 7, 2023

Rep. Peters, Scott H. [D-CA-50]

ID: P000608

Top Contributors

10

1
SYCUAN BAND OF THE KUMEYAAY NATION
OrganizationEL CAJON, CA
$3,300
Apr 19, 2024
2
SYCUAN BAND OF THE KUMEYAAY NATION
OrganizationEL CAJON, CA
$3,300
Apr 21, 2023
3
ARISON, MADELEINE
N/A • NOT EMPLOYED
IndividualCORAL GABLES, FL
$3,300
Oct 27, 2023
4
ARISON, MICKY
CARNIVAL CRUISE • CHAIRMAN
IndividualCORAL GABLES, FL
$3,300
Oct 27, 2023
5
EMERSON, LANGSTON
MINDSET • POLICY ADVISOR LOBBYIST
IndividualWASHINGTON, DC
$3,300
Oct 18, 2023
6
EPSTEIN, DANIEL J.
CONAM • REAL ESTATE EXECUTIVE
IndividualSAN DIEGO, CA
$3,300
Dec 20, 2023
7
GATES, WILLIAM H III
BREAKTHROUGH ENERGY • PHILANTHROPIST
IndividualREDMOND, WA
$3,300
Oct 19, 2023
8
GONZALEZ, JOHN MICHAEL
TIBER CREEK GROUP • PARTNER
IndividualWASHINGTON, DC
$3,300
Dec 13, 2023
9
LINDEN, LAWRENCE
N/A • RETIRED
IndividualNEW YORK, NY
$3,300
Nov 24, 2023
10
LINDEN, LAWRENCE
N/A • RETIRED
IndividualNEW YORK, NY
$3,300
Nov 24, 2023

Rep. Vindman, Eugene Simon [D-VA-7]

ID: V000138

Top Contributors

10

1
LUX FOR VIRGINIA
OrganizationLADYSMITH, VA
$500
Mar 29, 2024
2
LUX FOR VIRGINIA
OrganizationLADYSMITH, VA
$500
Mar 31, 2024
3
FORSTER-BURKE, DIANE
NOT EMPLOYED • NOT EMPLOYED
IndividualCOTTONWOOD HEIGHTS, UT
$4,000
Apr 20, 2024
4
FORSTER-BURKE, DIANE
IndividualCOTTONWOOD HEIGHTS, UT
$4,000
May 5, 2024
5
VON STEIN, THOMSON
IndividualROCKVILLE, MD
$3,500
Aug 7, 2024
6
HULL, MEGAN
SELF • ACTIVIST
IndividualWASHINGTON, DC
$3,300
Nov 2, 2024
7
KAISER, GEORGE
GBK CORPORATION • EXECUTIVE
IndividualTULSA, OK
$3,300
Oct 25, 2024
8
PARSONS, KATHLEEN
NOT EMPLOYED • NOT EMPLOYED
IndividualPOTOMAC, MD
$3,300
Oct 18, 2024
9
STAPLE, HARISE
SELF • MD
IndividualLOS ALTOS, CA
$3,300
Oct 18, 2024
10
HOLMES, LAURA
SELF • REAL ESTATE INVESTOR
IndividualBOCA RATON, FL
$3,300
Oct 22, 2024

Rep. McClellan, Jennifer L. [D-VA-4]

ID: M001227

Top Contributors

10

1
BARONA BAND OF MISSION INDIANS
OrganizationLAKESIDE, CA
$1,500
May 24, 2023
2
BARONA BAND OF MISSION INDIANS
OrganizationLAKESIDE, CA
$1,500
May 24, 2023
3
CHEROKEE NATION
OrganizationTAHLEQUAH, OK
$1,000
Dec 21, 2023
4
CHEROKEE NATION
OrganizationTAHLEQUAH, OK
$1,000
Dec 21, 2023
5
STARLEY LLC
OrganizationNORTH CHESTERFIELD, VA
$250
Oct 13, 2024
6
STARLEY LLC
OrganizationNORTH CHESTERFIELD, VA
$250
Oct 13, 2024
7
RICE, NANCY
LITTLE DIFFICULT RUN • CONSULTANT
IndividualVIENNA, VA
$6,600
Sep 23, 2024
8
RICE, NANCY
LITTLE DIFFICULT RUN • CONSULTANT
IndividualVIENNA, VA
$6,600
Sep 23, 2024
9
ABRAMSON, RONALD D
BUCHANAN INGERSOLL & ROONEY • ATTORNEY
IndividualWASHINGTON, DC
$3,300
Nov 15, 2023
10
FRIED, BARBARA J.
FRIED COMPANIES INC. • REAL ESTATE DEVELOPMENT
IndividualCROZET, VA
$3,300
Dec 19, 2023

Donor Network - Rep. Joyce, John [R-PA-13]

PACs
Organizations
Individuals
Politicians

Hub layout: Politicians in center, donors arranged by type in rings around them.

Loading...

Showing 63 nodes and 32 connections (53 secondary connections hidden)

Total contributions: $88,300

Top Donors - Rep. Joyce, John [R-PA-13]

Showing top 16 donors by contribution amount

16 Individuals

Industry Impact

Which industries are materially affected by specific provisions in this bill. 1 helped.

  • +Telecommunicationsconfidence 0.95

    Section 2 amends the Communications Act to streamline deployment of telecommunications or broadband service facilities in public and railroad rights-of-way, reducing procedural barriers and costs for providers (e.g., no payment required for work in public rights-of-way intersecting railroad corridors, standardized notification and scheduling). This benefits telecommunications companies by facilitating faster, cheaper deployment of infrastructure.

Who funds the sponsor on these industries

For each industry this bill affects, here's what the sponsor (Rep. Joyce, John [R-PA-13])received from donors associated with that industry during the 2022–present cycles. Donations are not proof of intent — they are a record of who funds the people writing the law.

Industries this bill HELPS

Project 2025 Policy Matches

This bill shows semantic similarity to the following sections of the Project 2025 policy document.AI-enhanced analysis provides detailed alignment ratings.

Department of Transportation

Moderate
Vector: 58%
Pages: 658-660AI Enhanced

AI Analysis:

"The bill focuses on streamlining broadband deployment in public and railroad rights-of-way, which aligns with Project 2025's broader goal of reducing regulatory barriers to facilitate technology deployment that can support transportation systems (e.g., connected vehicles and ITS). However, the bill does not directly address automated vehicles, spectrum allocation for transportation safety, or the specific DOT initiatives outlined in the Project 2025 excerpt, resulting in only moderate thematic o"

Key themes:infrastructure deploymentregulatory streamliningtechnology facilitationstakeholder coordination

— 625 — Department of Transportation security, and privacy without hampering innovation. DOT can oversee the testing and deployment of a wide variety of new technologies, allowing communities and individuals to choose what best fits their needs. It is the role of the private sector, not the government, to pick winners and losers in technology development. If a technology underperforms, the private sector should be liable, not the government. The department should ensure a tech-neutral approach to addressing any emerging transportation technology while keeping safety as the number one priority. As part of this, it should work to facilitate the safe and full integration of automated vehicles into the national transportation system. Over time, these advanced technologies can save lives, transform personal mobility, and provide additional transportation opportunities—including for people with disabili- ties, aging populations, and communities where car ownership is expensive or impractical. NHTSA’s and FMCSA’s current regulations were written before the advent of automated vehicles and driving systems. Both operating administrations have issued Advance Notices of Proposed Rulemakings (ANPRMs) that begin the pro- cess of updating their regulations to reflect this new technology. However, these regulations have stalled under the Biden Administration, which has chosen to use the department’s tools to get people to take transit and drive electric vehicles instead of helping people to choose the transportation options that suit them best. l NHTSA should work to remove regulatory barriers by focusing on updating vehicle standards as well as publishing performance-based rules for the operations of automated vehicles (AVs). l FMCSA should work to clarify the regulations to align with DOT’s AV 3.0 guidance, which would allow the drivers to be safely removed from the operations of a commercial motor vehicle. From a nonregulatory point of view, DOT has pivoted from a successful focus on the voluntary sharing of data to improve safety outcomes to adoption of a more compulsory and antagonistic approach to mandating data collection and publica- tion through a Standing General Order related to automated vehicles. This needs to be reversed. Many of these new and innovative technologies rely on wireless communica- tions that depend on the availability and purchase of radio frequency spectrum, a trend that is consistent with what we see in connectivity in our everyday lives. There is a role for DOT in ensuring that in the fight over spectrum, transportation gets its fair share. For technologies to work in transportation, and in particular to work for transportation safety, they have to meet the unique needs of a transportation — 626 — Mandate for Leadership: The Conservative Promise environment. They need to account for rapidly moving and out-of-line-of-sight vehicles as well as pedestrians, bicyclists, and other road users. They should account for the potential for radio interference, and they should address security. This is why in 1999, in response to a request from Congress, the Federal Com- munications Commission allocated the 5.9 GHz band of spectrum to traffic safety and intelligent transportation systems (ITS). In 2020, the FCC took away 45 MHz of the 75 MHz it had added, leaving only 30 MHz for transportation safety and ITS. DOT needs to represent the transportation community and make the case for needed spectrum to the public and Congress. CORPORATE AVERAGE FUEL ECONOMY (CAFE) STANDARDS One reason for the high numbers of injuries on American roadways is that national fuel economy standards raise the price of cars, disincentivizing people from purchasing newer, safer vehicles. Congress requires the Secretary of Transportation to set national fuel econ- omy standards for new motor vehicles sold in the United States. This mandate was established in the Energy Policy and Conservation Act of 1975 (EPCA),6 a law passed in the wake of the Arab oil embargo to promote greater energy efficiency and lessen the national security threat of U.S. dependence on foreign oil. The stat- ute directs DOT to prescribe the “maximum feasible” mileage requirements for different categories of internal-combustion engine (ICE) automobiles for each model year. The standards must be achievable using available ICE technologies running on gasoline, diesel fuel, or similar combustible fuels and must not be set so high as to prevent automakers from profitably producing new vehicles at sufficient volume to meet consumer demand. Congress recognized that the ICE-powered automobile has been instrumen- tal to advancing the mobility and prosperity of the American people and that the domestic mass production of new ICE vehicles generates millions of jobs and remains critical to the overall health of the U.S. economy and the strength of the nation’s industrial base. Accordingly, Congress took care to ensure that the mileage requirements issued by DOT would not undermine the vitality of America’s auto industry or interfere with the market economics that drives consumer demand for new vehicles. This rulemaking authority, which has been delegated by the Secretary to the National Highway Traffic Safety Administration, is exclusive to DOT. EPCA expressly preempts states from adopting or enforcing any different requirement “related to fuel economy standards” for new motor vehicles. While the statute instructs DOT to consult with the Department of Energy and the Environmental Protection Agency (EPA) in formulating its standards, no other federal agency, including EPA, has clear authority to set fuel economy requirements in place of NHTSA. The Clean Air Act7 gives EPA general authority to establish emissions

Department of Transportation

Moderate
Vector: 58%
Pages: 658-660AI Enhanced

AI Analysis:

"The bill aligns with Project 2025's emphasis on reducing regulatory barriers to technology deployment and improving coordination for infrastructure integration, particularly in leveraging existing rights-of-way for broadband expansion that supports connected transportation technologies. Both prioritize streamlining processes to enable private-sector-led innovation in transportation-related infrastructure."

Key themes:regulatory streamlininginfrastructure coordinationprivate sector innovationtransportation connectivityrights-of-way utilization

— 625 — Department of Transportation security, and privacy without hampering innovation. DOT can oversee the testing and deployment of a wide variety of new technologies, allowing communities and individuals to choose what best fits their needs. It is the role of the private sector, not the government, to pick winners and losers in technology development. If a technology underperforms, the private sector should be liable, not the government. The department should ensure a tech-neutral approach to addressing any emerging transportation technology while keeping safety as the number one priority. As part of this, it should work to facilitate the safe and full integration of automated vehicles into the national transportation system. Over time, these advanced technologies can save lives, transform personal mobility, and provide additional transportation opportunities—including for people with disabili- ties, aging populations, and communities where car ownership is expensive or impractical. NHTSA’s and FMCSA’s current regulations were written before the advent of automated vehicles and driving systems. Both operating administrations have issued Advance Notices of Proposed Rulemakings (ANPRMs) that begin the pro- cess of updating their regulations to reflect this new technology. However, these regulations have stalled under the Biden Administration, which has chosen to use the department’s tools to get people to take transit and drive electric vehicles instead of helping people to choose the transportation options that suit them best. l NHTSA should work to remove regulatory barriers by focusing on updating vehicle standards as well as publishing performance-based rules for the operations of automated vehicles (AVs). l FMCSA should work to clarify the regulations to align with DOT’s AV 3.0 guidance, which would allow the drivers to be safely removed from the operations of a commercial motor vehicle. From a nonregulatory point of view, DOT has pivoted from a successful focus on the voluntary sharing of data to improve safety outcomes to adoption of a more compulsory and antagonistic approach to mandating data collection and publica- tion through a Standing General Order related to automated vehicles. This needs to be reversed. Many of these new and innovative technologies rely on wireless communica- tions that depend on the availability and purchase of radio frequency spectrum, a trend that is consistent with what we see in connectivity in our everyday lives. There is a role for DOT in ensuring that in the fight over spectrum, transportation gets its fair share. For technologies to work in transportation, and in particular to work for transportation safety, they have to meet the unique needs of a transportation

Financial Regulatory Agencies

Moderate
Vector: 57%
Pages: 879-881AI Enhanced

AI Analysis:

"The bill focuses on streamlining broadband deployment by reducing regulatory barriers, which aligns with the Project 2025 FCC goal of unleashing economic prosperity through faster infrastructure buildout, though it does not address the FCC's specific priorities on Big Tech regulation, Section 230, transparency, or national security."

Key themes:broadband deploymentregulatory streamliningeconomic prosperityinfrastructure buildout

— 847 — Federal Communications Commission The FCC has facilitated the transition from 3G to 4G and now 5G offerings in two ways. First, it has freed spectrum—the airwaves needed to deliver wireless ser- vices. Second, it has preempted state and local siting and permitting laws that could otherwise slow down the buildout of next-generation infrastructure. One of the FCC’s great success stories from 2017 to 2020 was securing U.S. leadership in 5G. The FCC also administers an approximately roughly $9 billion-a-year program called the Universal Service Fund (USF), which has been funded by a line-item charge that traditional telephone companies add to consumers’ monthly bills. Expenditures from this fund subsidize rural broadband networks and low-income programs as well as connections for schools, libraries, and rural health care facil- ities. Through various COVID-era laws, Congress has also provided the FCC with a one-time $24 billion appropriation for various low-income initiatives. POLICY PRIORITIES The FCC needs to change course and bring new urgency to achieving four main goals: l Reining in Big Tech, l Promoting national security, l Unleashing economic prosperity, and l Ensuring FCC accountability and good governance.15 Reining in Big Tech. The FCC has an important role to play in addressing the threats to individual liberty posed by corporations that are abusing dominant positions in the market. Nowhere is that clearer than when it comes to Big Tech and its attempts to drive diverse political viewpoints from the digital town square. Today, a handful of corporations can shape everything from the information we consume to the places we shop. These corporate behemoths are not merely exercising market power; they are abusing dominant positions. They are not simply prevailing in the free market; they are taking advantage of a landscape that has been skewed—in many cases by the government—to favor their business models over those of their competitors. It is hard to imagine another industry in which a greater gap exists between power and accountability. That is why a new Adminis- tration should support FCC action on several fronts. Specifically, the FFC should: l Eliminate immunities that courts added to Section 230. The FCC should issue an order that interprets Section 230 in a way that eliminates the expansive, non-textual immunities that courts have read into the statute. — 848 — Mandate for Leadership: The Conservative Promise As one of the FCC’s previous General Counsels noted, the FCC has authority to take this action because Section 230 is codified in the Communications Act.16 The FCC’s Section 230 reforms should track the positions outlined in a July 2020 Petition for Rulemaking filed at the FCC near the end of the Trump Administration.17 Any new presidential Administration should consider filing a similar or new petition. As Justice Clarence Thomas has made clear, courts have construed Section 230 broadly to confer on some of the world’s largest companies a sweeping immunity that is found nowhere in the text of the statute.18 They have done so in a way that nullifies the limits Congress placed on the types of actions that Internet companies can take while continuing to benefit from Section 230. One way to start correcting this error is for the FCC to remind courts how the various portions of Section 230 operate. At the outset, the FCC can clarify that Section 230(c)(1) does not apply broadly to every decision that a platform makes. Rather, its protections apply only when a platform does not remove information provided by someone else. In contrast, the FCC should clarify that the more limited Section 230(c)(2) protections apply to any covered platform’s decision to restrict access to material provided by someone else. Combined, these actions will appropriately limit the number of cases in which a platform can censor with the benefit of Section 230’s protections. Such clarifications might also include drawing out the traditional legal distinction between distributor and publisher liability; Section 230 did not do away with the former, nor does it collapse into the latter. l Impose transparency rules on Big Tech. Today, Big Tech offers a black box. After Google manipulates search results, a small business can see its web traffic drop precipitously overnight for no apparent reason, potentially flipping its outlook from black to red. On Facebook, social media posts are left up or taken down, accounts suspended or permanently banned, without any apparent consistency. Out of the blue, YouTube can demonetize individuals who have risked their capital and invested their labor to build online businesses. At present, the FCC requires broadband providers to comply with a transparency rule that can provide a good baseline for Big Tech. Under the FCC’s rule, broadband providers must provide detailed disclosures about practices that would shape Internet traffic—from blocking to prioritizing or discriminating against content. The FCC could take a similar approach to

Showing 3 of 5 policy matches

About These Correlations

Policy matches are calculated using a hybrid approach: initial candidates are found using semantic similarity between bill summaries and Project 2025 policy text, then an AI model (Llama 3.1 70B) provides detailed alignment ratings and analysis. Ratings range from 1 (minimal alignment) to 5 (very strong alignment). This analysis does not imply direct causation or intent.

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