Winnebago Cooperative Telephone Association
704 East Main
Lake Mills, Iowa 50450

KENNETH LEIN, Manager
Phone (515) 592-6105

April 11, 1996

William F. Caton
Acting Secretary
Federal Communications Commission
Room 222
1919 M Street, NW
Washington, DC 20554

SUBJECT: WINNEBAGO COOPERATIVE TELEPHONE ASSOCIATION'S
COMMENTS ON CC DOCKET 96-45 FEDERAL-STATE
JOINT BOARD ON UNIVERSAL SERVICE

Dear Mr. Caton:

The Federal Communications Commission (FCC) is seeking comments on what services should be supported by the Universal Service support mechanisms and how to calculate the support.

In resolving the myriad of issues presented by the legislation, the Commission must assure that the universal service goals and principles established by the 1996 Act are met. In order to preserve and advance universal service, as required by the legislation, the Commission should build on current programs rather than attempt to create new procedures from scratch. Existing universal service programs, including USF, Lifeline Assistance, DEM weighting, and CCL support (LTS) should be mandated with minimal disruption. Rules governing these programs can be adapted with transitions where necessary to make current support mechanisms explicit. The Lifeline Assistance rules provide a model for a support program for new services, such as discounted services to rural health care providers, educational institutions and libraries.

New costing methodologies, such as cost proxies, could be allowed on an optional basis but not mandated, especially for small rural carriers. The Commission should also replace the current PSL-based contribution mechanism with a revenue-based contribution system applicable to all carriers, as required by the 1996 Act.

Finally, the Commission should appoint NECA as administrator of the new universal service funding mechanism. NECA has proven itself capable of administering support funds in a fair, efficient and neutral manner. One-third of NECA's board now consists of directors outside the telephone industry. As a means of broadening participation in fund administration, the Commission could consider creating a universal service advisory council. Such a council could include fund recipients, contributors, state regulators, and consumer representatives, with members to be selected by constituent groups.

I appreciate your positive consideration of my comments.

Very truly yours,

Kenneth Lein
Manager