 592 (1976). 75 Burford, 319 U.S. at 327. 76 RCA, 358 U.S. at 346, 347-48. Antitrust as Applied to Network Industries federalism was not implicated. As the Court noted in Cantor, "Congress could hardly have intended state regulatory agencies to have broader power than federal agencies to exempt private conduct from the antitrust laws. Therefore, the standards for ascertaining the existence and scope of [this] exemption surely must be at least as severe as those applied to federal regulatory legislation" (428 U.S. at 596-97). Interestingly, the Supreme Court's decisions on primary jurisdiction and Burford abstention added a third consideration: the differences in institutional com- petence between antitrust courts and regulatory agencies. For example, the Court's opinion in RCA underscored that, in addition to the need to avoid conflicting man- dates, primary jurisdiction was also based in part on "the need for administrative skill commonly to be found only in a body of experts in handling the intricate facts" needed to regulate an industry (358 U.S. at 346 (internal quotation marks omitted)). 77 Burford similarly relied on the need to allow state agencies and the state courts reviewing those agencies' decisions "to acquire a specialized knowledge which is useful in shaping the policy of regulation of the ever-changing demands in this field" (319 U.S. at 327). Concerns about institutional capabilities also appeared in lower court decisions applying primary jurisdiction to the telecommunications industry, which based the doctrine in part on "the court's lack of expertise with the subject matter of the agency's regulation" (MCI, 496 F.2d at 220). d. Implications for the Essential Facilities Doctrine Considerations of institutional competence have particular resonance for the essen- tial facilities doctrine. Commentators have recognized that the doctrine necessarily presupposes some form of price regulation. In the absence of price regulation, the owner of the bottleneck facility would simply provide access at the mo