ely to emerge in the near term (U.S. House 1995). As the D.C. Circuit has noted, wholesale access provides a "completely synthetic" form of competition (U.S. Telecom Ass'n, 290 F.3d at 424; Covad, 450 F.3d at 548). Because all firms are providing service on the same network, there is no opportunity for firms to compete either by lowering cost or by providing innovations in service. Herbert Hovenkamp describes the type of competition in the following terms: Imagine that a town has only one seller of bananas, which is the local Kroger grocery store. Seeking to promote banana competition, the town passes a banana competition ordinance requiring Kroger to sell bananas at a steeply discounted wholesale price to individual entrepreneurs who push banana carts around the store, perhaps underselling Kroger itself by a few cents. In this case Kroger supplies the store facility, storage, heat, light, and even the bananas themselves, with the small sellers supplying little more than their labor. The banana competition ordinance simply confuses competition with large numbers of retailers. True banana competition would require individual stores with their own facilities, purchasing bananas on the market and retailing them to consumers. Nevertheless, this is what the 1996 Telecommunications The Regulation of Local Telephone Networks Act does. Small CLECs can lease most of their inputs from the Bells and even locate some of their equipment on Bell property. They are entitled to purchase the equipment and services they need at regulated wholesale prices, and then resell the services in competition with the Bells. (Hovenkamp 2004, pp. 369-70) It is for this reason that most commentators have found little value in the type of competition induced by wholesale access (Joskow and Noll 1999; Beard et al. 2001; Rosston and Noll 2002; Ness 2006). Under wholesale access, the only way that providers can compete with one another is by squeezing their profit margins until prices converge to cost. Regulatory authorities could dissipate any re