emergence of a new type of companies known as competitive access providers (CAPs). CAPs initially focused on offering long- distance bypass services, which allowed corporate customers to place long-distance telephone calls without having to access the Bell System's local telephone facilities. The eventual expansion of CAP networks to cover the entire core business dis- tricts of major metropolitan areas made it possible for CAPs to begin to offer local telephone service in direct competition with the incumbents. CAP-provided services possessed many advantages over those provided by the incumbent local telephone companies. First, CAP networks tended to employ more modern technology, which allowed them to offer a greater range of features and a more attractive price structure than could the incumbent local telephone companies. 7 Unlike the incumbents, moreover, CAPs were not required to provide uniform services according to published tariffs approved by the FCC. As a result, they were able to respond more quickly to market demands and to tailor pricing and terms of service to each customer's needs. Last, the untariffed nature of CAP services also allowed them to avoid the cross subsidies embedded in the system of access charges created by the FCC. The FCC recognized that the emergence of CAPs meant that some local tele- phone calls would originate on one carrier's network and terminate on another's. The incumbent local telephone company could use its dominant position to fore- stall the CAPs' ability to compete effectively, either by interconnecting with the CAPs on unattractive terms or by refusing to interconnect with them altogether. Thus, if CAPs were to compete with the incumbent local telephone companies, they needed to interconnect with the incumbent networks on the same terms and conditions that the incumbent provided for their own circuits. As a result, the FCC's Expanded Interconnection proceeding gave CAPs the right to interconnect with the incumbent's network on nondiscriminatory terms. As part of this 