 needs, but rather on what would inflict the greatest harm on the network owner. A network owner may wish to hedge against this possibility by maintaining excess capacity in case one of its competitors decides to request access to a key portion of its network. This has the drawback of forcing the network owner to make capital investments that may never be used. Indeed, competitors that are acting strategically may well take into account whether the network owner maintains such excess capacity when deciding whether and where to request access. If so, the mere fact that the network owner has added excess capacity to hedge against the possibility of a strategic access request effectively guarantees that access will be sought elsewhere. The emergence of local telephone competition has begun to provide market benchmarks that can obviate the need to establish interconnection access rates through regulation. As noted earlier, wireless telephone services have successfully emerged as direct competitors to wireline telephony. The emergence of the wire- less industry is important because wireless-to-wireless interconnection is currently unregulated. As a result, the terms of interconnection between wireless carriers are determined through arms-length negotiations that can provide precisely the type of external benchmark needed to determine the market value of transport and call termination services. Admittedly, interconnection between wireless carriers does involve somewhat different considerations than interconnection with incumbent 31 The FCC allowed for two alternatives. First, state public utility commissions could adopt a proxy range set by the FCC (at 0.2 and 0.4 cents per minute for termination) (FCC 1996c). The Eighth Circuit struck down the use of proxy prices in Iowa Utilities Board V. FCC, 219 F.3d 744, 756-57 (8th Cir. 2000), rev'd on other grounds sub nom. Verizon Commc'ns, Inc. V. FCC, 535 U.S. 467 (2002). This portion of the Eighth Circuit's decision does not appear to have been challenged before the Supreme 