cal calling areas and thus a higher "value of service." It did not take a mathematical genius to figure out that competition using UNEs would thus be most profitable in urban areas and unprofitable in many rural areas. (It also begs the question of how rural ILECs can be profitable while charging less than urban ones, but then the industry is rife with subsidies.) Plain old copper loops were not, of course, the only UNEs. The usual list of UNEs available from RBOCs included many other elements. Besides plain loops, there were ISDN loops, which sometimes had electronics needed to deliver ISDN beyond ordinary loop range, and there were DS1-speed loops, typically deployed using telephone company HDSL hardware, for so-called "T1" services. Dark fiber was also made available both as a loop and as an inter- office facility, albeit, like all UNEs, on an as-available basis. Raw interoffice bandwidth between ILEC offices (dedicated transport interoffice facilities) was also available as a UNE, generally at mileage rates that were a tiny fraction of special access tariff rates. For example, with most special access DS1 rates in the $20 per mile range, UNE DS1 mileage tended to run between a quarter and two bucks a mile. These usually required collocation to access. Operator services, directory assistance, Signaling System 7 ports, the line information database, multiplexors, and various other services were at least for a time available as UNEs, at TELRIC rates. Section 271 of the Act, which gave the RBOCs an avenue to enter the interLATA business, had its own 14-point checklist, which in some ways was a reiteration of the list of UNEs that was not actually specified elsewhere in the Act. Section 271 required RBOCs to provide CLECs with loops, interoffice facilities, local switches, operator services, and pretty much everything else CLECs Winning Strategies Are Met by Rule Changes needed to be a CLEC. It did not independently specify a pricing standard, though. For that matter, neither did the Act; it was merely assumed, at