[1]/ Federal State Joint Board on Universal Service, Notice of Proposed Rulemaking and Order Establishing Joint Board, CC Docket 96-45 (released March 8, 1996) ("Universal Service Notice").

[2]/ Common Carrier Bureau, Preparing for Addressing Universal Service Issues: A Review of Current Interstate Support Mechanisms, pg. 26 (Feb. 23, 1996) ("Universal Service Survey") [emphasis added, footnotes omitted].

[3]/ Universal Service Survey at pp. 28-29.

[4]/ D. Kline, Align and Conquer, 3.02 WIRED 100, 164 (Feb. 1995).

[5]/ Universal Service Survey at pp. 53, 66 (1995 estimate for DEM weighting).

[6]/ Because the proxy cost models submitted in this proceeding develop cost data for all census blocks, the standard deviation of census block costs could be easily be used to set the appropriate threshold percentage to identify the most costly 5, 10 or 15 percent of census blocks.

[7]/ Universal Service Notice at [[paragraph]][[paragraph]] 25-26.

[8]/ There was agreement that core services include: (1) access to the public switched network with the ability to place and receive voice grade calls; (2) touch-tone services; (3) single party service; (4) access to emergency services (911); and (5) access to operator services. Universal Service Notice at [[paragraph]] 16.

[9]Whichever benchmark cost model the Joint Board chooses to use may need to be modified to reflect the costs of the loop transmission standard imposed on rural carriers.

[10]/ 47 U.S.C. [[section]] 254(c)(3).

[11]/ 47 U.S.C. [[section]] 254(h)(1)(B).

[12]/ 47 U.S.C. [[section]] 254(h)(1)(A).

[13]/ 47 U.S.C. [[section]] 254(h)(2)(A).

[14]/ 47 U.S.C. [[section]] 153(14) (customer premises equipment), (45) (telecommunications equipment) and (46) (telecommunications services).

[15]/ Access to Communications for Education Coalition Comments at pg. 7; State of Alaska Comments at pp. 10-13; Alaska Library Association Comments at pg. 3; Alaska Public Utilities Commission Comments at pp. 1-6 (28.8Kb should be minimum speed); Alaska Telephone Association Comments at pp. 2-3 (ISDN); America's Carriers Telecommunications Association at pg. 6; American Association of Community Colleges and the Association of Community College Trustees Comments at pp. 10-12 (T1 access, Internet connectivity); American College of Nurse Practitioners Comments at p. 2 (ISDN); American Library Association Comments at pp. 4, 9-12; American Telemedicine Association Comments at pg. 7 (112Kb should be minimum); Ameritech Comments at pp. 14-15; Apple Computer Comments at p. 4 (bandwidths ranging from 128Kb to 45Mb should be made available); BellSouth Comments at pg. 19 (DS1 or 1.544Mb for schools); California Department of Consumer Affairs Comments at pg. 22; California Library Association Comments at pg. 3; Governor of Guam Comments at pp. 7, 10 (ISDN, access to NII); Idaho Public Utilities Commission Comments at pg. 11 (providers should contribute access to the Internet); Iowa Communications Network Comments at pg. 2; Iowa Utilities Board Comments at pg. 2; Kinkos, Inc. Comments at pp. 3-6 (community Internet access should be part of universal service); Lincoln Trail Libraries System Comments at pg. 1; Commonwealth of Massachusetts Board of Library Commissioners Comments at pg. 4; Merit Network, Inc. Comments at pp. 2-3 (ISDN, T1 access); Library of Michigan Comments at pg. 4 (ATM, broadband access); Michigan Library Association Comments at pg. 5 (ATM, broadband access); State of Missouri Comments at pp. 1-3 (Internet, teleconferencing capabilities); Mountaineer Doctor Television Telemedicine Program at West Virginia University (T-1 access, ISDN, ATM); National School Boards Association et al. Comments at pp. 13-14, Appendix I (unbundled broadband switching and transmission capable of delivering high-quality video); Nebraska Association of Hospitals and Health Systems Comments at pg. 1 (384Kb minimum, 1.544Mb more likely); New York State Board of Regents and new York Education Department Comments at pg. 11 (broadband on demand); North of Boston Library Exchange, Inc. Comments at pg. 1 (T-1, T-3 access); North Dakota Department of Health Comments at pg. 1 (ISDN); Oakland Unified School District Comments at pp. 10, 13 (T-1 access); Pacific Telesis Comments at pp. 3-6, 8-11 (ISDN provided to schools); U.S. Distance Learning Association Comments at pp. 9-12; US West Comments at pp. 21-23 (56/64Kb on request); and State of Wisconsin Department of Public Instruction Comments at pg. 1.

[16]/ 47 U.S.C. [[section]]706(a).

[17]/ Universal Service Survey at pp. 78-89.

[18]/ 107 Stat. 1356, codified in 7 U.S.C. [[section]] 935 (1994).

[19]/ 7 U.S.C. [[section]]935(d)(3)(B). [emphasis added]

[20]/ 7 C.F.R. [[section]]1751.106 et seq.

[21]/ Ameritech Comments at pp. 15-16.

[22]/ Of course, incumbent carriers have begun deploying electronics in some loop plant. MFS does not seek to "turn back the clock." Rather, the incumbent should be required either to permit competing carriers to collocate wherever it installs loop electronics or it should provide high-speed access from those points to the host central offices. These details are more appropriately addressed in the Commission's interconnection docket, but the Commission and Joint Board should establish the general requirement in this proceeding.

[23]/ ADSL (Asymmetric Digital Subscriber Line) is a technology that uses local loops to provide video or data services by transmitting digital information from the network to the user at rates from 1.5Mb to 6Mb and transmitting from the user to the network at 576Kb per second. HDSL (High-Bit-Rate Digital Subscriber Line) is a new technology that allows DS1 level transmission on two copper wire pairs or a half of a DS1 transmission capability on a single copper wire pair.

[24]/ American Library Association Comments at pp. 13-19.

[25]/ Winstar Comments at pp. 1-2.

[26]/ The major peering points in the United States include MAE (Metropolitan Area Ethernet) East (in Washington, D.C.), MAE West (in San Jose, CA), MAE Chicago, MAE Dallas, Commercial Internet Exchange ("CIX" in Santa Clara, CA), Chicago NAP, and New York NAP.

[27]The Commission already has reached this conclusion in its Interconnection proceeding ([[paragraph]][[paragraph]] 96-98) concerning CMRS versus landline exchange areas. The concern will be compounded as cable television and power companies enter the market with their non-coincident franchise areas.

[28]/ Universal Service Notice at [[paragraph]][[paragraph]] 112-115.

[29]/ 47 C.F.R. [[section]] 69.116(a).

[30]/ Universal Service Notice at [[paragraph]] 123 citing Assessment and Collection of Regulatory Fees for Fiscal Year 1995, Price Cap Treatment of Regulatory Fees Imposed by Section 9 of the Act, Report and Order, 10 FCC Rcd 13512 (1995).

[31]/ 47 U.S.C. [[section]]153(51) [emphasis added].