[2] Any one doubting this proposition only need review the FCC's decision adopting access charges, where the Commission specifically noted that universal service was one of its four main objectives in establishing access charges. MTS and WATS Market Structure, 93 FCC2d. 241, 251 (1983) recon 97 FCC2d. 682, 683 (1983). In addition, it can be argued that all other contribution (price in excess of incremental cost) is a critical funding aspect of universal service. This would include, most notably, the Residual Interconnection Charge (RIC) associated with switched access transport. However, on the question of loop costs and loop costs recovery there isn't any question that the current interstate EUCL and CCL are interstate universal funding mechanisms with the clear aim of keeping basic rates low.

[3] For example, assume Company A receives $100M from EUCL and CCL and Company B receives $105M. Assume under a "national benchmark rate" cost proxy comparison Company A is entitled to only $90M while Company B can now claim $125M. Each company's jurisdictional assignment to the interstate jurisdiction would need to be changed to match the new interstate payments.

[4] The states, or individual school districts or other local governing bodies, will be responsible for funding the deployment of infrastructure such as inside wire and hardware as well as content, software, training and systems support.

[5] We note that not all health care providers should be eligible for purchase credits or other discounts. The industry represents a wide spectrum of "not for profit" and "for profit" service providers. Ideally, the Commission should narrow the recipients to non-profit providers with a demonstrated need for funding. We believe Section 254(h)(1)(A)'s limitation of eligibility for funding to "health care providers for rural areas" and its requirement only of reasonably comparable rates for services to rural health care providers as to urban customers, dictate only that rural health care providers not be charged more than other customers. Thus, we assume the Commission will not interpret Section 254(h) to require blanket discounts to health care providers, especially to those without economic need.

[6] Pacific Bell's CCLC also includes long term support (LTS), which is money collected on behalf of companies participating in the NECA pool. LTS is designed to help equalize CCLC rates between price-cap and non-price-cap companies, and this is a subsidy to NECA company loop costs.