atory authorities 2 W. Union Tel. Co. V. Esteve Bros., 256 U.S. 566, 573 (1921); Clay County Produce Co. V. W. Union Tel. Co. (Unrepeated Message Case), 44 I.C.C. 670, 673-74 (1917). White V. W. Union Tel. Co., 33 I.C.C. 500 (1915); Malone V. N.Y. Tel. Co., 40 I.C.C. 185 (1916); Commercial Cable Co. V. Sw. Union Tel. Co., 45 I.C.C. 33 (1917); Whittaker V. W. Union Tel. Co., 59 I.C.C. 286 (1920). See generally U.S. House (1934, p. 69) observing that "it is known to everyone that the Interstate Commerce Commission has never found it practical to do anything toward the regulation of telephone rates." Sharfman (1931, p. 110) observes that "[i]n practice, there has been no extensive exercise of these broad powers" over interstate communications by the ICC. Robinson (1989, p. 7) notes "a general consensus that the ICC did not aggressively implement its new mandate." The Regulation of Local Telephone Networks condoned Bell System's monopolization of all aspects of the telephone network. Monopoly control in turn allowed regulators to authorize charging above cost for certain services and use the excess returns to cross-subsidize below-cost service for other services. For example, the FCC used its control over the separations process to allocate to long-distance rates an ever-increasing proportion of the costs of the capital equipment used to provide both local and long-distance service, such as telephone handsets, the wires connecting individual customers' premises to central offices (commonly known as "local loops"), and the switching equipment located in central offices. The higher long-distance charges were thus used to keep monthly charges for local telephone service low. State regulatory authorities similarly used higher charges on business users to cross-subsidize the rates paid by residential users. Finally, regulatory authorities used a system known as "rate averaging" to mandate that all telephone subscribers in the state pay the same rates for service. The effect was to require lower-cost urban users to cross-s