 repugnancy" standard requires that the agency have imposed affirmative obligations on the regulated entity. Mere agency jurisdiction over particular conduct is not enough. Thus in United States V. Radio Corp. of America (RCA), the Supreme Court held that the fact that conduct was subject to FCC regulation under the public interest standard was not enough to exempt it from the antitrust laws (358 U.S. 334, 345-46 (1959)). Similarly, in Otter Tail, the Court held that a federal agency's residual authority to compel access as "necessary or appropriate in the public interest" in the electric power industry did not satisfy the requisites for implied exemption from the antitrust laws. On the contrary, in forgoing direct agency regulation of interconnection, Congress had "rejected a per- vasive regulatory scheme in favor of voluntary commercial relationships. When these relationships are governed in the first instance by business judgment and not regulatory coercion, courts must be hesitant to conclude that Congress intended to override the fundamental national policies embodied in the antitrust laws" (410 U.S. at 372-75; see also Gordon, 422 U.S. at 692-93 (Stewart, J., concurring)). As a result, a wide range of lower courts have rejected claims that the federal regulatory scheme overseen by the FCC immunizes telephone companies' refusals to allow other companies to interconnect with their networks from antitrust scrutiny. Although 47 U.S.C. § 201(a) authorizes the FCC to mandate interconnection if it finds that doing SO is "necessary or desirable in the public interest," Otter Tail established that such residual authority to order interconnection is insufficient to confer implied immunity. Even though the FCC has the right to review tariff filings presenting the terms and conditions under which telephone companies will permit others to interconnect with their networks, in practice it can only investigate a small percentage of them.5 The fact that the vast majority of tariff filings go into effect without FCC review a