Court. The Regulation of Local Telephone Networks LECs. Direct comparisons are complicated by the significant differences in uti- lization rates as well as the emergence of wireless pricing schemes that do not differentiate between local and long distance service. The comparison is rendered more complicated by the fact that wireline telephony is based on a calling-party- pays regime, whereas in wireless both calling and receiving parties pay for their own connectivity. In addition, the ratio of usage costs to access costs is much higher for wireless networks than for wireline networks. The analysis is further obscured by the fact that such interconnection between wireless carriers is often accomplished indi- rectly through the LECs (FCC 2000b). 32 Still, as wireless and other facilities-based competitors grow, rates charged for interconnection between wireless competitors will continue to emerge as a market-based reference point that can be used to resolve pricing problems. The number of external benchmarks will only continue to grow as local cable operators and other types of broadband providers begin to offer local telephone service. In the absence of external benchmarks based on actual market transactions, resort to some cost-based second-best measure of market value becomes necessary. As noted earlier, economic theory suggests that cost-based measures should follow ECPR, which sets rates as the sum of the direct incremental costs of providing an input and the opportunity costs that the incumbent incurs when the new entrant provides the services instead of the incumbent. 33 The opportunity should include not only the lost profit opportunities associated with access, but also the value of the network facilities rendered useless by the diversion of network elements to competitors. TELRIC includes elements designed to reflect the direct costs, but not the opportunity costs. The key problem with the FCC's analysis is its refusal to include any factor to reflect opportunity cost. In setting prices without consideri