Review of Industrial Organization 16: 219–223, 2000. © 2000 Kluwer Academic Publishers. Printed in the Netherlands. 219 Discussant Comments on Papers by Andrew Joskow, Daniel Rubinfeld, and Janusz Ordover and Margaret Guerin-Calvert MARIUS SCHWARTZ ⋆ U.S. Department of Justice, Antitrust Division, Washington DC 20530, U.S.A. Rather than attempting to discuss all three papers in detail, let me concentrate on a few main themes. I will devote most of the discussion to Andrew Joskow’s paper, which addresses competition in telecommunications since the 1996 Telecommuni- cations Act – an issue of considerable interest to me given my prior and ongoing work in this area. Joskow The paper covers two main topics: entry into long-distance (interLATA) services by the Regional Bell Operating Companies (RBOCs) under Section 271 of the Tele- com Act; and mergers between large incumbent local phone companies (ILECs, such as the RBOCs or GTE) that operate in non-overlapping local territories. I agree substantially with the paper’s analysis and only wish to expand on a few points. RBOC Entry into Long Distance. The DOJ’s standard for recommending FCC ap- proval of an RBOC’s long-distance application in a state requires that the RBOC’s local market in that state must first be fully and irreversibly open to competition. 1 ⋆ Economics Director of Enforcement, Antitrust Division, U.S. Department of Justice, and Pro- fessor of Economics, Georgetown University (on leave). These discussant comments do not purport to reflect the views of the Department of Justice. 1 Among other things, this entails showing that the new arrangements needed for local competition (such as operations support systems through which competitors can interface elec- tronically with the incumbent) are in place, and that a track record of their performance has been established so as to prevent backsliding by an RBOC once it receives long-distance au- thority. See Evaluation of the United States Department of Justice (DOJ), In the Matter of Application of SBC Communications Inc. et al. Pursuant to Section 271 of the Telecommu- nications Act of 1996 to Provide In-Region, InterLATA Services in the State of Oklahoma, FCC, CC Docket 97-121, May 16, 1997 (www.usdoj.gov/atr/public/comments/sec271/sbc/sbc.htm).