that market could exist without ILEC switching. Primary rate ISDN and channelized T1 services, used for both PBX trunks and modem pools, were The Great Telecom Meltdown also relatively competitive because, by 2001, there were many central office switch vendors capable of supporting those services, and prices for T1 switching ports had fallen to a fraction of their pre-1996 levels. CLECs had spurred switching technology; the ILECs could argue that in most major markets, there was plenty of CLEC switching capacity available. CLECs could, after all, buy from each other. It was only a slight problem that most CLECs did not choose to sell wholesale to each other or did not bother to create mechanisms for the purpose. CLECs looked at each other as competitors when they could have focused on the ILECs, whose market share was still many times their own. Not that wholesaling was always easy: CLECs typically used loop carriers based on the GR-303 standard, which were built to talk to a single switch and thus could not often directly connect to two different CLECs' switches. EELs Created an Opportunity to Serve Businesses In 1999, the FCC created a rule by which unbundled dedicated interoffice transport-cheap T1 pipes-could be ordered in combination with an unbun- dled DS1 loop, to any of the ILEC's central offices in the LATA, without requiring collocation at the subscriber's serving CO. This allowed, for example, a CLEC in Newark, N.J., to provide T1-based service to customers in Hacken- sack, Hoboken, and Hohokus without requiring collocations in those localities. This combination of transmission UNEs was called an expanded extended loop, or EEL [4]. ILECs that refused to provide EELs had to provide unbundled DS1 switching in major markets instead; EELs became almost universally available. But EELs came with a catch. The lines, in order to qualify, had to carry a "sub- stantial" amount of "local" voice service, rather strictly defined and requiring written certification of compliance by the CLEC. This was to prevent spec