ely difficult (U.S. Telecom Ass'n V. FCC, 188 F.3d 521, 524-27 (D.C. Cir. 1999); Bernstein and Sappington 1999; Vogt 1999). The empirical literature is divided on whether price caps lead to lower or higher rates; compare, for example, Mathios and Rogers (1989) and Kaestner and Kahn (1990) with Knittel (2004). The emergence of competition in portions of the telecommunications industry has provided some impetus toward eliminating tariffing requirements. The FCC's attempts to detariff long distance following the breakup of AT&T represent a prime example. Because MCI and Sprint did not hold a dominant position in the long Networks in Telecommunications distance market, the FCC tried to exempt them from having to file tariffs (FCC 1982, 1983a, 1985a). As AT&T lost its dominant position, the FCC eventually exempted it from having to file tariffs as well (FCC 1995c). The courts rejected the FCC's actions, holding that the agency lacked the discretion to forbear from enforcing the tariff requirement mandated by the statute (MCI V. AT&T, 512 U.S. 218 (1994); MCI V. FCC, 765 F.2d 1186 (D.C. Cir. 1985); AT&T V. FCC, 978 F.2d 727 (D.C. Cir. 1992); Southwestern Bell Corp. V. FCC, 43 F.3d 1515 (D.C. Cir. 1995)). Congress eventually amended the statute to give the FCC the discretion to forbear from enforcing the statutory tariff requirements when the agency found that doing SO would be in the public interest (47 U.S.C. § 160). The FCC has exercised its forbearance authority SO that at this point, long-distance services have been completely detariffed (FCC 1996d16). After initially ruling to the contrary, the FCC has also ruled that local telephone companies do not have a dominant position in offering broadband services such as digital subscriber lines (DSL) and thus do not need to file tariffs for those services (FCC C 2002e). A similar move is taking place in local phone service, as competition from wireless services is leading local phone companies to request detariffing of rates. For example, Qwest asked the Idaho Public Uti