rates are often as high as 3 cents a minute at each end of an intrastate call and about 1 cent a minute for interstate calls originating and terminating on nonrural local carriers' networks. The marginal cost of switched access is undoubtedly less than 0.1 cents a minute for today's electronic switching systems. In 1996 the large incumbent local carriers reported $20 billion in switched access rev- enues. By 2002, the most recent year for which data are available, they had declined to $10.5 billion in switched access charge revenues. 12 Today they are still about $8 billion. These elevated access charges on fixed-wire networks are in severe dan- ger because of the enormous shift of long-distance services to wireless car- riers. By originating a long-distance call on a wireless handset, the sub- scriber reduces the number of access minutes by at least 50 percent. If the subscriber calls another wireless subscriber, the reduction is 100 percent. Not only are switched access minutes not growing as rapidly as in the 1990s, but they are declining steadily, and-as already shown-access rev- enues are following the same path. In response, the fixed-wire carriers have attempted to engineer a regulatory solution known as "bill and keep" that would reduce access charges to zero. 13 Each local carrier would trans- port its traffic to or from a node on the network, and the loss in access rev- enues would be recovered from a fixed charge levied on the local subscriber. Unfortunately, this proposal is now faltering, in part because the local car- riers do not believe they can pass on the increased fixed charge to their cus- tomers. 14 This surely suggests that the incumbent fixed-wire "monopolists" have very little market power in today's environment of wireless and VoIP competition. As a result, the FCC and state regulators are likely to have dif- ficulty persuading incumbents to reduce access charges appreciably; they will simply have to watch as their second source of subsidies withers away in the face of wireless and VoIP c