[2]E.g., MCI at 10; Teleport at 7; U S West at 8.

[3]The BCM appears to be a moving target, with continuing changes that attempt to improve upon problems its critics raise.

[4]A second proxy proposal, submitted by Pacific Telesis, has been correctly challenged because it is proprietary and cannot be priced out or adequately evaluated. E.g., Rural Telephone Coalition at 16; Teleport at 8.

[5]Telecommunications Resellers Association at 12. Another supporter, Teleport (pp. 7-8), adds to the list of BCM shortcomings, criticizing the BCM's mistaken assumption that the population density in Census Block Groups is uniform.

[6]BellSouth, Appendix, K. Gordon and W.E. Taylor, Comments on Universal Service at 36-40 (April 12, 1996).

[7]TDS showed in its Reply Comments in CC Docket No. 80-286 that small LEC costs are too varied for capture by a proxy.

[8]GVNW accurately points out (p. 15) that "reimbursement of actual cost is an absolute way to assure that companies have used the support for the intended purpose."

[9]See, NECA at 10-11; Southwestern Bell at 2-3.

[10]E.g., Rural Telephone Coalition at 15-16; USTA at 16; Southwestern Bell at 17; JSI at 6-9; NECA at 6-7. See, also, Wyoming PSC at 2, 17-18.

[11]For example, rural needs inspired sections 254(e); 251(f); 253(b) and (f); 254; and 259.

[12]Section 254(b)(2) and (3).

[13]WRTA at 10-12; United Utilities at 2.

[14]See, U S West at 11.

[15]J.C. Panzar, The Continuing Role for Franchise Monopoly in Rural Telephony, pp. 7-9 (1987).

[16]NECA at 9-10; Rural Telephone Coalition at 11-13.

[17]As explained infra, the need for disaggregation of high cost recovery is not confined to the case of another eligible carrier.

[18]Rural Telephone Coalition at 15.

[19]E.g., Wyoming PSC at 5; South Carolina PSC at 2; Pennsylvania PUC at 25.

[20]E.g., Colorado Independent Telephone Association at 2; Frederick & Warriner at 4.

[21]Rural Telephone Coalition at 19; Oregon and Washington Independent Telephone Association at 16-17; Missouri PSC at 21.