alls, such as conference calling or free adult chat-line services. These customers then advertised their conference calling and chat-line services on the Internet as free services. The result in one case was for terminating traffic for 175 customers to jump from 15,000 minutes to 6.4 million minutes in a five-month span and a transfer payment of $10-15 million to these small LECs (Omaha World Herald 2007). Networks in Telecommunications access charges used by the incumbent LEC with which the new entrant competes can be used as a benchmark for determining the reasonableness of the new entrant's terminating access charges (FCC 2001d, Uri 2001). A complete resolution of this issue exceeds the scope of this chapter. For our purposes, determining which of these different mechanisms would best promote consumer welfare is less important than the fact that institutional mechanisms may exist for solving the terminating access problem that do not require imposing an access mandate. 4. Platform Access Platform represents the type of access most often granted through regulation. For example, the FCC's Part 68 Rules, which can be traced to the FCC's landmark decision in Carterfone, have long required the Bell System to open its local telephone networks to all providers of CPE. As a result of MCI's long battle with AT&T, the FCC has also required the Bell System to open its local telephone network to all providers of long-distance services. Furthermore, the FCC's Computer Inquiries required local telephone companies to open their networks to all providers of information services. As we shall discuss in greater detail in the next chapter, similar mandates were included in the consent decree breaking up AT&T and the related consent decree regarding GTE. In each case, this regulation is properly regarded as platform access, because it involves opening up the network to providers of complementary services. The Telecommunications Act of 1996 essentially left this system undisturbed. With respect to long distance, 47 U.S.C. $ 251(c)