[1] The Citizens Companies and their interest in this proceeding are described in their initial comments in this proceeding, filed April 12, 1996.

[2] See Public Notice, DA 96-1078, released July 3, 1996.

[3] In the Matter of Amendment of the Commission's Rules and Polices to Increase Subscribership and Usage of the Public Switched Network, CC Docket No. 95-115, Notice of Proposed Rulemaking, 10 FCC Rcd. 13003 (1995).

[4] Section 3(51) of the Act.

[5] Section 3(48) of the Act.

[6] Section 3(38) of the Act.

[7] The Citizens Companies evaluated these models with regard to their California local exchange properties and the California Public Utilities Commission's universal service proceedings (R. 95-01-020; I. 95-01-021). A lack of the significant computer, software and manpower resources prohibit the Citizens Companies from conducting a detailed analysis of these models as applied to their properties in the many other states in which they operate.

[8] Although these models are generally based on TSLRIC principles, not all are adequate or appropriate in their assumptions of network technology, configuration or expenses. In the California universal service proceedings, the Citizens Companies supported the Pacific Bell Cost Proxy Model as the most appropriate choice.