d the FCC have expressed reluctance to address takings issues until a particular methodology has been embodied into an actual rate order, they have suggested that Networks in Telecommunications the principles of confiscatory ratemaking or regulatory takings are likely to govern such challenges. The problem with this analysis is that it focuses on TELRIC as a general matter without focusing on the constitutional implications of the 1996 Act's physical collocation provisions. As the FCC has itself recognized, both interconnection and access to unbundled network elements typically require the network owner to permit requesting carriers to place equipment in its central office on an indefinite basis. As a matter of first principles laid out in Chapter 7, the physical collocation associated with interconnection and unbundled access provisions represents the type of permanent physical invasion deemed to constitute a per se taking under the Supreme Court's decision in Loretto. 37 This conclusion has been reinforced by a number of lower court decisions reviewing different aspects of the 1996 Act. For example, the D.C. Circuit's decision in Bell Atlantic held that the physical collocation regime upon which the FCC modeled its implementation of the 1996 Act constituted a physical taking (24 F.3d at 1445-47). This conclusion draws further support from the D.C. Circuit's decision in GTE Service Corp. V. FCC, in which the court repeatedly emphasized its concern that the FCC's interpretation of the physical collocation provisions may result in "unnecessary takings" of LEC property (205 F.3d 416, 421, 423, 426 (D.C. Cir. 2000)). Most instructive of all is the decision of the Court of Federal Claims in Qwest Corp. V. United States, which is one of the few decisions to address the merits of a takings challenge to the 1996 Act. In that case, a requesting carrier obtained access to fourteen loops that served one particular customer and connected those loops to its own switching equipment contained in a collocation cage located in t