 (47 U.S.C. § 251(c)(3)). In addition to the phys- ical elements employed to provide service, such as transport, switching, signaling, and local loops, unbundled access also involves equipment used in the manage- ment of network elements. Also, unbundled access involves equipment used in the management of the network itself. However, unbundled access under the 1996 Act extends far beyond the network element layer. The ILEC must also supply access to call-related databases, such as those used for line information, number portability, toll-free calling, operator services/directory assistance, and the advanced intelli- gent network database. These databases are at higher logical layers such as element management, network management, or even service management (FCC 2003e). 14 In addition, ILECs also must provide services that are based on bundles of ele- ments, such as the local loop, switching, and transport. Combinations of elements extend the requirements of unbundled access to higher logical layers of the network firm, particularly to network management and service management. These activ- ities entail organizational costs that are part of the transaction costs of providing unbundled access. Moreover, the ILEC must also provide CLECs with access to its OSS. This moves UNE access to the highest logical layer - business management systems. This form of UNE access extends regulatory control far beyond network elements into the back office and business management of the network firm. The transaction costs involved in such access are potentially significant because they reach into the very management of the network firm. Under traditional cost-of-service regulation of telecommunications, electric power, and natural gas utilities, regulators deferred to company management in their control of the firm and confined their attention to rate making and related activities. UNE regulation that extends to regulation of the network firm's manage- ment controls has the potential to be significantly more intrusive. Further granti