e third generation wireless devices ("3G") are fully deployed, competition in the wireless industry is likely to provide sufficient competition to drive market prices toward efficient levels. As noted in Chapter 4, after some reluctance to regard wireless as competitive with conventional local telephony, competition from wireless carriers has led the FCC to begin the process of deregulating local telephone service. Once that is completed, the distortions associated with retail access will disappear. 2. Wholesale Access Policymakers have also experimented with various forms of wholesale access over the years. The issue first arose when the New York Public Service Commission (NYPSC) and the FCC approved Rochester Telephone's voluntary decision to spinoff its local telephone network into a separate company that would offer basic network services to all comers on a wholesale basis (NYPSC 1994; FCC 1995b). Wholesale access was mandated without structural separation by the resale pro- visions of the Telecommunications Act of 1996, which required all companies providing local telephone service on the day the statute was enacted "to offer for resale at wholesale rates any telecommunications service that the carrier provides at retail to subscribers" (47 U.S.C. § 251(c)(4)(A)). The Pennsylvania Public Util- ity Commission (2001), although rejecting requests to divide Verizon's wholesale and retail units into separate companies, nonetheless required Verizon to provide wholesale access to Verizon's competitors. For the reasons we discuss at greater length in Chapter 5, wholesale access can adversely affect network performance. As noted in the discussion on retail access, unexpected deviations in demand can alter the optimal network configuration. The fact that demand under wholesale access depends on two prices - the prices of retail and wholesale access - renders the impact of wholesale access on network demand ambiguous. Depending on these two prices, network demand may either increase or decrease, which in turn adversely