ork firm must also develop systems that communicate with com- petitors to receive orders for the services of network elements. These systems are analogous to the internal systems of the network firm that formerly communicated information about the need for network elements to provide final services to retail customers. Under unbundled access, the incumbent firm's network effectively cre- ates a host of new services that are needed for serving customers who wish to lease network elements. Just as with wholesale access, unbundled access requires ILECs to provide external interfaces to allow for information exchange with the information systems of CLECs for the leasing of UNEs. The extension of unbundled access also requires systems integration between ILECs and CLECs. The provisioning of a multitude of UNEs requires substantially more detailed software and hardware systems for EDI for gathering CLEC orders and billing for usage of UNEs. These transaction costs are not part of the TELRIC calculation, which is based on the cost of elements to the incumbent network firm. Yet transaction costs can be substantial when SO many specific elements are involved. Transaction costs may outweigh equipment costs when facilities leasing involves relatively limited capacity usage. The notion in the 1996 Act that UNEs should be accessed at any technically feasible point manifestly ignores the economic cost of transactions, because some points of access will be more cost-efficient than others. This issue concerns trans- action costs as well. Because of the potentially significant information costs of providing and billing specific network elements, unbundled access should reflect the most efficient means of access in terms of transaction costs for incumbents and their competitors. D. The Possibility of Regulatory Arbitrage Organizing the different types of access into distinct categories inevitably poses significant definitional challenges, particularly in an industry undergoing dynamic Economic Effects of Regulating Access to Netwo