ss to the entire UNE platform at very low rates in negotiations over merger approvals and Sec- tion 271 approvals for entry into long distance. Most notably, Verizon (then Bell Atlantic) was forced to allow access to the entire platform in New York as an FCC condition for approval of its acquisition of Nynex in 1999. As a result, CLECs have amassed 30 percent of all switched access lines in New York, nearly double their share of lines in the rest of the country. FCC, Local Telephone Competition, table 7. 17. Ibid., tables 3 and 4. 18. Ibid., tables 3 and 5. I am indebted to Tim Tardiff for this insight. 19. Robert W. Crandall, Allan T. Ingraham, and Hal J. Singer, Do Unbundling Policies Discourage CLEC Facilities-Based Investment? Berkeley Electronic Papers, Topics in Eco- nomics and Policy Research (University of California at Berkeley, 2004). 20. The NRRI study contains the relevant rates that CLECs must pay to operate UNE loops in the fifty states, plus the District of Columbia. Some of the rates are final, and oth- ers were under ongoing negotiation as of the July 2001 NRRI study, but all rates are the best available representation of the UNE cost in the respective state. See Billy Jack Gregg, A Sur- vey of Unbundled Network Element Prices in the United States (NRRI, Spring 2001). Excluded from the analysis are states that do not publish their average UNE rates: Alaska, Arkansas, California, Colorado, Florida, Hawaii, Louisiana, Missouri, North Dakota, New Mexico, Ohio, Rhode Island, South Carolina, and South Dakota. 21. For each state, the number of E911 lines and the number of UNE loops for 2000 and 2001 were provided by the regional Bell operating companies (RBOCs) that provide local telephone service in that state. For states where more than one RBOC operates, we subtract the sum of the UNE loops across each RBOC in that state from the number of CLEC lines in the E911 database. 22. The E911 data are from twenty-three states and cover 2000 and 2001; the FCC data are from thirty-five states and cover the tw