ng discretion to the network firm's competitors as to what types of management sys- tems are to be accessed only worsens the situation. It is difficult to evaluate the transaction costs of such unbundled access, because management control systems are at the heart of the incumbent firm's decisions about revenues and costs. Suffice it to say that the costs of such interference are potentially equal to the value of the network firm itself. This suggests that regulatory forbearance is preferable to cost recovery for management control systems. In the absence of unbundled access, the network elements remain at the most basic logical layer of the network. They are the capital equipment that provides services within the context of overall network organization. Network elements provide service inputs to the element management layer, which in turn provides services to the network management layer. Network management integrates the 14 This order was vacated on other grounds on judicial review (U.S. Telecom Ass'n V. FCC, 359 F.3d 554 (D.C. Cir. 2004)). Networks in Telecommunications many individual elements into a coordinated whole. Service management receives as its inputs the network's output of services that are integrated to form final services. These services are then given to the business management layer, which in turn presents these final services as products to the customers of the network firm. Unbundled access short-circuits this process, bypassing the internal governance of the network firm. The business management of the network firm must procure the services of individual network elements and bundles of elements. To main- tain the system's logical layers requires a fundamental change in organizational structure. The network firm must develop systems that monitor usage of network elements for the purposes of leasing transactions with competitors who have un- bundled access to those elements. The network firm must create systems that internally provision the services of network elements for competitors. The netw