Verizon Communications Inc. v. FCC, 535 U.S. 467, 36 (2002)

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502

VERIZON COMMUNICATIONS INC. v. FCC

Opinion of the Court

iterate that the breadth and complexity of the Commission's responsibilities demand that it be given every reasonable opportunity to formulate methods of regulation appropriate for the solution of its intensely practical difficulties"). See generally Chevron, supra, at 843-845, 866 ("When a challenge to an agency construction of a statutory provision, fairly conceptualized, really centers on the wisdom of the agency's policy, rather than whether it is a reasonable choice within a gap left open by Congress, the challenge must fail").20 The incumbents nevertheless field three ar-20 While Justice Breyer does not explicitly challenge the propriety of Chevron deference, he relies on our decision in Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Automobile Ins. Co., 463 U. S. 29, 56 (1983), to argue that the FCC's choice of TELRIC bears no "rational connection" to the Act's deregulatory purpose. See post, at 542, 554 (opinion concurring in part and dissenting in part). State Farm involved review of an agency's "changing its course" as to the interpretation of a statute, 463 U. S., at 42; these cases, by contrast, involve the FCC's first interpretation of a new statute, and so State Farm is inapposite to the extent that it may be read as prescribing more searching judicial review under the circumstances of that case. (Indeed, State Farm may be read to suggest the obverse conclusion, that the FCC would have had some more explaining to do if it had not changed its course by favoring TELRIC over forward-looking methodologies tethered to actual costs, given Congress's clear intent to depart from past ratesetting statutes in passing the 1996 Act.)

But even on Justice Breyer's own terms, FCC rules stressing low wholesale prices are by no means inconsistent with the deregulatory and competitive purposes of the Act. As we discuss below, a policy promoting lower lease prices for expensive facilities unlikely to be duplicated reduces barriers to entry (particularly for smaller competitors) and puts competitors that can afford these wholesale prices (but not the higher prices the incumbents would like to charge) in a position to build their own versions of less expensive facilities that are sensibly duplicable. See n. 27, infra. See also infra, at 515-516 (discussing FCC's objection to Ramsey pricing). And while it is true, as Justice Breyer says, that the Act was "deregula-tory," in the intended sense of departing from traditional "regulatory" ways that coddled monopolies, see supra, at 488 (remarks of Sen. Breaux), that deregulatory character does not necessarily require the FCC to employ passive pricing rules deferring to incumbents' proposed methods and

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