P. 0. Box 147-107 Opp Street, Rock Port, MO 64482 816/744-5311

Comments of Rock Port Telephone Company
Re: CC Docket 96-45 Federal-State Joint Board on Universal Service

Comments USF NPRM
Docket # 96-45 FCC#96-93

Rock Port wishes to file comments regarding docket 96-93. Rock Port is an average schedule company that receives no Universal Service Funding.

We have adequate density and are financially sound enough to provide universal service without the fund, however, we strongly believe the Universal Service Fund is necessary.

We are happy that the U.S. Congress also understands the importance of Universal Service and addressed the necessity of continuing a Universal Service Fund in the 1996 telecom legislation.

We understand that the 96 legislation will provide for a Universal Service Fund and that an entity will be created to administer the new fund.

We ask that the commission have N.E.C.A. administer the new fund. NECA is well equipped with data and appropriate personnel to provide this service to the telecommunications industry. NECA has already established a relationship with the industry and the FCC in its current function as pool administrator.

In defining the services to be supported by the Universal Service Fund, Rock Port Telephone Company asks that the commission consider supporting services with actual costs that are greater than 125% of national average costs. The services logically will include areas that are low in density and higher cost in nature to provide service to.

Any service defined as Universal Service by the joint boards new definition as well as rural residential & business, low density, high cost areas should be included as eligible recipients of the Universal Service Fund.

Support mechanisms will need to take the form of pooling. All carriers shall pay into the fund to establish a level of funding and qualified services should receive from the fund. These mechanisms should probably take 2 Jurisdictions, interstate as one and intrastate as the other.

NECA is in a good position to provide key information to the F.C.C. in helping establish the fund.

Rock Port Telephone Company believes that the FCC did a good thing to serve the public, as well as the industry, when it created NECA and we encourage the FCC to utilize when implementing the telecom 96 legislation.

In the transition Rock Port Telephone Company seeks to continue the interim cap on USF and would suggest that a subscriber line charge be transitioned in as other support decreases. Any subscriber line charge implemented should not exceed an additional $3.00 per access line for residential and or business. We suggest residential and business share cost increases equally because there is already an increased cost on business.

Rock Port Telephone Company believes that while some subscriber line charge increase is necessary and reasonable, long term IXC support and service provider pooling must also be retained. Perhaps the support by IXCs and LECs could be reduced but not eliminated.

Rock Port Telephone Company believes that competition as mandated in the 96 Telecom Legislation will tend to equalize service deposits and other service provision issues. In short: (Whoever serves the consumer best will get the largest market share.)

Rock Port believes that life line and link up programs will be assigned to the carrier of last resort. The provider of those services should be entitled support from the current forms of support. These services need to be supported as fully as possible as long as carriers are obligated to provide these services.

We realize that our comments may lack in professional or legal presentation but hope that the commission will consider our position on these issues.

Thank you,

Boyd D. Spiker, C.E.O.
ROCK PORT TELEPHONE COMPANY