ng applied, and the two carriers divvied up the access revenues based on a formula that took into account which carrier actually owned what share of the interoffice facilities.) When the Telecom Act passed, most of the CAPs that became the first CLECs wanted to be treated the same as independents, with bill and keep. This made sense to them because their early customers, mostly large businesses, typi- cally made more local calls than they received. High-volume call centers, after all, typically used 800 numbers, which were not local interconnection. The ILECs recognized this, and they had experience with cellular interconnection, in which more than twice as many calls were typically originated than terminated by the cellular network. So they fought hard against bill and keep, with emo- tional pleas like this from Bell Atlantic: The most blatant example of a plea for a government handout comes from those parties who urge the Commission to adopt a reciprocal compensation CLECs Winning Strategies Are Met by Rule Changes price of zero, which they euphemistically refer to as 'bill and keep. A more appropriate name, however, would be 'bilk and keep,' since it will bilk the LECs' customer out of their money in order to subsidize entry by the likes of AT&T, MCI, and TCG.7 The FCC's Local Competition Order thus imposed a system called recipro- cal compensation. It hinged on this wonderfully ambiguous wording in Section 251(b)5 of the Telecom Act, describing the duties of "all local exchange carriers" (and thus including both ILECs and CLECs): (5) Reciprocal Compensation. The duty to establish reciprocal compensation arrangements for the trans- port and termination of telecommunications. The FCC decided that this did not apply to toll calls, because the switched access system was already in place, but that CLECs and ILECs should, in gen- eral, pay each other to terminate local calls. The rate that each paid would, how- ever, almost always be the same, SO if traffic were in balance, the fees would net to zero. The aforement