sire to promote classical-style democracy that permeates his jurisprudence. A more cynical observer might sug- gest that his interest in protecting investors from market fluctuations followed more from the fact that he held a substantial amount of his wealth in commercial paper issued by utilities (Zacharias 1988). Networks in Telecommunications quickly became one of the focal points in the debate over rate-setting methodolo- gies. The Supreme Court has frequently invoked it to justify regulatory authorities' use of cost-based pricing when setting rates (Verizon Commc'ns Inc. V. FCC, 535 U.S. 467, 481-85 (2002); Duquesne Light Co. V. Barasch, 488 U.S. 299, 308-09 & n.5 (1989); Fed. Power Comm'n V. Natural Gas Pipeline Co., 315 U.S. 575, 603 (1942) (Black, J., concurring)). Eventually, however, the controversy between historical and replacement cost ended in a somewhat inconclusive draw. Rather than resolving this dispute on its substantive merits, the Supreme Court ultimately invoked notions of administrative deference and judicial restraint to resolve not to strike down any rate for its failure to adhere to any particular methodology. Instead, the Court opted to uphold any rate SO long as it fell within a broad zone of reasonableness (Fed. Power Comm'n V. Hope Natural Gas Co., 320 U.S. 591, 602 (1944); Duquesne, 488 U.S. at 314-16). Applying these principles allowed the Court to sustain a wide variety of ratemaking methodologies based on increasingly complicated versions of historical or replace- ment cost (Verizon, 535 U.S. at 497-517, 523-8 (replacement cost); Duquesne, 488 U.S. at 310-12 (historical cost); Permian Basin Area Rate Cases, 390 U.S. 747, 761, 768-74 (1968) (historical cost for an entire area rather than a single firm); Hope Natural Gas, 320 U.S. at 596-98, 603-05 (historical cost)). The unifying thread in all of these approaches was their consistent commitment to basing rates on direct cost (whether historical or replacement cost) and their consistent refusal to include a component taking opportu