ifficulties in determining reasonableness of rates as justification for "leav[ing] the question of reasonableness to the companies themselves"); cases cited and reviewed in Areeda and Hovenkamp (2008b, pp. 4-7). Areeda acknowledges that compelling access is more justifiable where the monopolist is a consor- tium that can admit additional members or where a regulatory agency already exists to control the terms of dealing. Antitrust as Applied to Network Industries SO much for access and SO little for the product it sells in competition with the plaintiff that the latter cannot earn a reasonable profit. The disputes, moreover, will not be limited just to price. The parties are likely to disagree on nonprice terms and conditions as well. Should the demand outstrip the existing capacity, compelled access would force network owners not merely to sell out of excess capacity, but to reduce their own output or expand their plants in order to service rivals. As a result, mandating access requires "price regulation of the kind undertaken by regulatory agencies - something for which both the federal courts and the antitrust litigation process are extremely ill-suited and which is, in any event, inconsistent with antitrust's fundamental 'market' orientation to problems of lack of competition" (Areeda and Hovenkamp 2008c, pp. 195, 275-80, 338). Other commentators have drawn similar conclusions. These criticisms of antitrust courts' institutional competence to oversee access mandates are part of a broader debate about the relative merits of structural and conduct remedies.82 Richard Posner's statistical study of antitrust enforcement (1970) distinguished between "once-for-all" decrees that render a market struc- turally competitive and thereafter do not require continuing judicial oversight, and "regulatory" decrees, which require antitrust courts to maintain continuing super- visory relationships. Posner questioned the institutional competence of courts to superintend regulatory decrees. In addition to requiring scrutiny over