ess to backtrack somewhat in 1992, when it reinstated cable rate regulation and mandated must carry as a statutory matter. At the same time, it strengthened leased access and limited municipal authority by prohibiting the issuance of exclusive franchises (Statutes at Large 1992, pp. 1465-66, 1471-82, 1484-85). Congress reversed course again when it included provisions in the Telecommunications Act of 1996 once again deregulating cable rates (Statutes at Large 1996, p. 116). 6 This order was affirmed on judicial review (ACLU V. FCC, 523 F.2d 1344 (9th Cir. 1975)). 7 FCC (1972); U.S. Senate (1983); U.S. House (1984). 8 See, e.g., City of New York V. FCC, 486 U.S. 57 (1988) (upholding federal preemption of state regulation of cable signal quality standards); Capital Cities Cable, Inc. V. Crisp, 467 U.S. 691, 704, 698-711 (1984) (upholding federal preemption of state regulation of carriage of cable signals and invalidating state regulation of cable advertising as inconsistent with federal regulation); Cmty. Commc'ns Co., Inc. V. City of Boulder, 455 U.S. 40, 48-49 (1982) (holding that the city's three-year moratorium on cable system expansion was not immune to federal antitrust scrutiny); FCC Midwest Video Corp., 440 U.S. 689 (1979) (invalidating federal leased access requirement for exceeding the FCC's authority). 9 See, e.g., Sloan Commission on Cable Communications (1971); Barnett (1972). 10 Quincy Cable TV, Inc. V. FCC, 768 F.2d 1434, 1440-43 (D.C. Cir. 1985). 11 FCC 1986b, pet. for review granted sub nom. Century Commc'ns Corp. V. FCC, 835 F.2d 292, 296-97 (D.C. Cir. 1987), clarified, 837 F.2d 517 (D.C. Cir. 1988). Networks in Telecommunications The regulation of cable modem service followed a similar pattern. The FCC repeatedly declined to resolve the regulatory classification that it thought should apply to cable, let alone decide the scope of any access obligations that might apply, with its reluctance to do SO drawing a rebuke from two members of the Supreme Court.12 In the absence of a clear assertion of fe