the Telecommunications Act of 1996 and by Global Crossing's acquisition of Rochester. During the period during which the Open Market Plan was in effect, the NYPSC (1998) acknowledged that "competition ha[d] yet to develop to any noticeable extent." Studies analyzing the wholesale access provisions of the 1996 Act have similarly concluded that wholesale access has failed to serve either as a basis for competition Networks in Telecommunications among resellers or as a stepping stone toward facilities-based competition. In fact, the growth of wholesale access appears to be correlated with a drop in investment in facilities by both new entrants and incumbents, a connection largely corrob- orated in financial analysts' reports. Likewise, abandonment of wholesale access was accompanied by a move toward facilities-based competition through VoIP and emerging wireless technologies (Hausman and Sidak 2005; Hazlett 2006). Indeed, competitors and financial analysts agreed that wholesale access was uneconomical as a competitive strategy. 3. Interconnection Access Interconnection access arises any time two local telephone companies serve the same calling area. Because of the Bell System's strategy of either acquiring competing local systems or ceding the field to those competitors that refused to merge, Bell-owned local telephone companies rarely operated in the same calling areas as independent local telephone companies. It did happen on occasion, such as in the Los Angeles area, where GTE and Pacific Bell both provided local service to different parts of the Los Angeles area. As noted earlier, after the emergence of CAPs providing local telephone service in central business districts, the FCC mandated interconnection access. The 1996 Act formalized this requirement by mandating that all incumbents provide interconnection access. Interconnection access disrupts network management to a much greater degree than retail and wholesale access. As noted in Chapter 5, the impact of interconnec- tion access on network demand is ambigu