Verizon Communications Inc. v. FCC, 535 U.S. 467, 93 (2002)

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Cite as: 535 U. S. 467 (2002)

Opinion of Breyer, J.

erence to a rate-of-return or other rate-based proceeding)," § 252(d)(1), makes sense from this point of view. It reflects Congress' desire to obtain not perfect prices but speedy results. It specifies that States need not use formal methods, relying instead upon bargaining and yardstick competition. See Iowa Utilities, supra, at 424-425 (Breyer, J., concurring in part and dissenting in part); cf. Order ¶ 631 (de-scribing how the New York Commission "se[t] prices on a case-by-case basis"). I recognize, however, that the FCC has rejected this approach in favor of extraordinarily complex national ratesetting standards, which we review only to determine whether they will further, or serve as obstacles to, the competitive marketplace that the statute seeks.

Fourth, the FCC adds that its system seeks to base rates on the costs a hypothetical "most efficient firm" hypothetically would incur were it "building from scratch." And such a system, in its view, will "simulate" or "best replicat[e], to the extent possible, the conditions of a competitive market." Order ¶ 679; see also id., ¶ 738. This response, however, does not do more than describe that very feature of the system upon which the critics focus their attack.

As I have previously said, supra, at 543, such an objective is perhaps consistent with an ordinary ratesetting statute that seeks only low prices. But the problem before us—that of a lack of "rational connection" between the regulations and the statute—grows out of the fact that the Telecommunications Act is not a typical regulatory statute asking regulators simply to seek low prices, perhaps by trying to replicate those of a hypothetical competitive market. Rather, this statute is a deregulatory statute, and it asks regulators to create prices that will induce appropriate new entry. See Part II, supra. That being so, we may assume, purely for argument's sake, that the FCC rules could successfully "replicate" the prices toward which perfectly efficient, perfectly competitive markets would tend. But see Kahn 326-327 (stating that such prices are never achieved in any actual

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