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In the Matter of		)
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Federal-State Joint Board	)		CC Docket No. 96-45
on Universal Service		)
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The Guam Public Utility Commission ("Guam PUC"), by its attorneys, hereby submits its comments in the above captioned proceeding instituted by the Federal Communications Commission ("FCC" or "Commission") on March 8, 1996.[1] The NPRM was released to implement Section 254 of the Communications Act of 1934 as amended by the Telecommunications Act of 1996.[2]

The Guam PUC's objective in this proceeding is to insure that the benefits of the Universal Service support mechanisms available to citizens in the continental United States are also made available to Guam citizens on a non-discriminatory basis.[3]

Section 254(b) of the 1996 Act establishes certain principles on which the Joint Board and the Commission are to base their policies for the "preservation and enhancement of universal service, " including: 1) the provision of "quality services" at "just, reasonable, and affordable rates"; 2) nationwide access to "advanced telecommunications and information services"; 3) access by consumers in "rural, insular, and high cost areas" to telecommunications and information services "reasonably comparable" to those in "urban" areas and at rates that are "reasonably comparable" to "urban" rates; 4) adoption of a requirement that all providers of telecommunications services make "equitable and nondiscriminatory" contributions to the preservation of universal service ; 5) establishment of "specific and predictable mechanisms to provide adequate and sustainable support for universal service"; 6) access to advanced services for healthcare providers, schools, and libraries; and 7) such other principles as the Joint Board determines are necessary and appropriate for the protection of the public interest, convenience, and necessity, consistent with the purposes of the Act.

Of particular interest to the GPUC is Section 254(b)(3) which requires access by consumers in "rural, insular, and high cost areas" to telecommunications and information services "reasonably comparable" to those in "urban" areas and at rates that are "reasonably comparable" to "urban" rates. As the Commission noted in the NPRM, Congress specifically intended "insular" areas to include the Pacific Island territories.[4] Thus, Guam citizens should be afforded all the benefits envisioned in Section 254, including access to all "universal services" identified by the Commission in this proceeding and at rates that are "reasonably comparable" to "urban" rates.

The GPUC looks forward to further participation in this proceeding.

Respectfully submitted,

_____________________

Philip L. Verveer
Brian A. Finley

WILLKIE FARR & GALLAGHER
Three Lafayette Centre
1155 21st Street, N.W.
Washington, D.C. 20036

April 12, 1996 Attorneys for the Guam Public Utilities Commission