Challenging traditional 3-layer/3-tier view of application

I just came across an interesting article by Rockford Lhotka at TheServerSide.net. In this article titled "The Fallacy of the Data Layer" Mr Lhotka insists that in a service oriented world we should not view data access as a layer but rather as a service. He quite rightly points that Data Sources usually are not maintained/owned exclusively by the application(service) (e.g think of SQL Server or any other data store) and hence they can not be thought of as an application layer. I believe he makes a valid point and it should be taken. So, next time in Service Oriented Context, don't think/call ur data access code a "layer", rather call it a "service".