n many cases it would likely be more efficient to have the last-mile provider carry out the functions previously performed by the unaffiliated ISP. The efficiency of having last-mile providers perform the functions previously performed by ISPs is demonstrated dramatically by the manner in which the mul- tiple ISP access mandated during the AOL-Time Warner merger has been imple- mented. Contrary to the original expectations of the FTC, the unaffiliated ISPs that have obtained access to AOL-Time Warner's cable modem systems under the FTC's merger clearance order have not placed their own packet networks and backbone access facilities within AOL-Time Warner's headends. Instead, traffic bound for these unaffiliated ISPs exits the headend via AOL-Time Warner's backbone and is handed off to the unaffiliated ISP at some external location. It is hard to see how consumers benefit from such arrangements, given that they necessarily use the same equipment and thus provide the same speed, services, and access to content regardless of the identity of the nominal ISP. The fact that these unaffiliated ISPs have found it more economical to share AOL - Time Warner's existing ISP facilities rather than build their own strongly suggests that integrating ISP and last-mile operations is more efficient. In other words, the technological structure of the narrowband made the inter- face between local telephone systems and ISPs a natural boundary between two different providers. The architectural changes wrought by the digitization of last- mile broadband technologies caused what was once a natural interface between Networks in Telecommunications market players to collapse. By requiring network owners to maintain standardized interfaces, platform access runs the risk of locking existing interfaces into place long after technological changes have rendered such an interface obsolete. Platform access can also increase transaction costs. Government establishment of a standardized interface requires considerable time and effort both by regula