• Gap in 1982 and 1988 Acts results in extensive FCC proceedings to expand wireline access until 1996

    • FCC proposes to expand definition of “essential” phones to common areas in workplaces and credit card phones (1988)

    • FCC withdraws common area proposal (1989)

    • Consumer petition for reconsideration gets FCC to expand definition to common areas (1990); FCC proposes expansion to all phones in workplaces, hotels, health care facilities by May 1992

  • Industry opposition to common area rule (partial reason: lack of labeling)