al process imposes a degree of transaction costs and delay. Furthermore, by forcing advance disclosure Networks in Telecommunications of rates, the tariffing process forces all firms to give their competitors advance notice of any changes in business strategies. In addition, rate regulation facilitates collusion by making information about price more transparent, making products more homogeneous, and providing a mechanism for enforcing any deviations from the established price. The enforced uniformity inherent in tariffs reduces network owners' ability to tailor product offerings to individual customers' particular needs. In addition, it has long been understood that deadweight loss can be minimized in high-fixed-cost industries by allocating greater proportions of those fixed costs to those customers that are least price-sensitive (and thus will reduce their con- sumption the least in response to pricing above marginal cost) (Ramsey 1927). The nondiscrimination aspects of retail access foreclose such welfare-enhancing possibilities. Perhaps most importantly, retail access can dampen incentives to invest in last-mile broadband technologies. Retail access will have no effect if regulators set retail access prices too high. On the other hand, setting retail access prices too low will reduce incentives for incumbents and competitors alike to invest in upgrading existing networks and in last-mile technologies. Regulators must thus thread a very narrow needle if retail access is to have any beneficial effect. Such a process would be difficult under the best of circumstances. It borders on the impossible with respect to technologies that are undergoing rapid innovation and differentiation and that are growing ever more complex. Most importantly, the presence of intermodal competition largely obviates the need for regulatory authorities to assume the burdens of implementing retail access. It is for this reason that commentators have generally criticized the possibility of imposing retail access on last-mile broadband se