esale. Hence these may be "essential facilities" to which the incumbent is re- quired to provide entrants access. 14 The use of unbundled network elements grew substantially once regu- lators began insisting that the entire complement of incumbent facilities be provided to entrants at these TELRIC rates, thereby essentially providing the entrant with the opportunity to resell the incumbent's services at a much larger wholesale discount.¹5 If the entrant used this entire UNE "platform," however, it sacrificed the flexibility to design its own network to offer new services. In other words, it simply obtained a resale option at a wider discount. Facilities-Based Entry An entrant into local telecommunications may choose to build its own network facilities, thereby allowing it the flexibility to develop new tech- nologies or offer new services. These facilities may be in the form of the fiber-optic/copper plant deployed by the incumbents, fiber-optic/coaxial cable deployed by cable television companies, fixed wireless facilities, cel- lular systems, or even satellite systems. While such entry is initially more expensive, it enables the entrant to differentiate its services from those of the incumbent. Equally important, it frees the entrant from the need to depend on its principal rival for maintaining and modernizing its network. Growth of the New Entrants Before 1996 there was little local mass-market competition in the U.S. telecommunications sector because state regulators generally discouraged local competition. A few competitive access providers (CAPs) had begun to build fiber rings in central business districts principally to interconnect large customers with long-distance carriers. State regulators could not block these entrants because they were providing a local service defined as "interstate access." However, the 1996 act opened all telecom markets to entry, includ- ing the local market for small business and residential subscribers. Entry began slowly in 1997-98, as total lines of competitive local exchang