, but it also provided them with a means of setting aside the remaining restrictions on their behavior that had been present since their creation. Section 271 of the Act contained a 14-point The Great Telecom Meltdown checklist of obligations that the Bells were expected to live up to. If their state regulatory commission and the FCC agreed that they met the terms, then they would be given authority to sell interLATA services in that state. This process was not terribly easy, at least at first: The FCC in effect under President Clinton, then led by William Kennard, held the compliance bar high. The checklist required the Bells to unbundle numerous network elements, including loops, switching, transmission, and operator services. The Section 271 process often focused on the operational support systems (OSS)-hideously complex com- puter programs used for ordering and provisioning services [5]. The Bells had to open their OSSs to the CLECs, allowing UNE Platform and resale orders to be placed efficiently. However, once the Bush administration's FCC, led by Michael Powell, took over, state approvals fell like dominoes. And Powell did not believe that the Bells really had to unbundle switching; after all, CLECs could purchase switches of their own. So by 2004, the Bells were, in most cases, the second-largest retail long distance providers in their respective territories. To be sure, their customer base was mostly low-revenue subscribers who preferred one bill to two. But the Bells' gain in long distance market share was not nearly matched by losses in local service market share. Between this loss of market share and the general decline in prices, the long distance business went into serious decline. The two-tier industry struc- ture of the MFJ was being eroded. True, the Section 271 rules required the Bells to deal with their own long distance subsidiaries at something vaguely resembling arms' length; they still had to allow their subscribers to maintain separate interLATA and intraLATA primary interexchange carrier 