[2] The services that the Notice proposed to support are (1) voice grade access to the public switched network, with the ability to place and receive calls, (2) touch-tone capability, (3) single party service, (4) access to emergency services (911), and (5) access to operator services. Notice, [[paragraph]] 16.

[3] See, e.g., Ameritech Comments at 7-8; Bell Atlantic Comments at 2-3; GTE Comments at 2; Southwestern Bell Telephone Company Comments at 8; USTA Comments at 13.

[4] See, e.g., Association of Local Telecommunications Services (ALTS) Comments at 9; MFS Comments at 16; Teleport Communications Group Comments at 6.

[5] See, e.g., AT&T Comments at 12; LCI Comments at 3; LDDS WorldCom Comments at 7-8; MCI Comments at 3-4.

[6] See, e.g., NCTA Comments at 5.

[7] See, e.g., Information Technology Industry Council Comments at 4; ITAA Comments at 4; Ad Hoc Telecommunications Users Committee Comments at 4.

[8] See, e.g., Florida PSC Comments at 6; Missouri PSC Comments at 4; cf. NARUC Comments at 10 (definition should not include advanced services).

[9] See CompTel Comments at 4-7.

[10] See, e.g., AT&T Comments at 12; Ameritech Comments at 7 n.11; Florida PSC Comments at 7.

[11] See, e.g., AT&T Comments at 12-13; Bell Atlantic Comments at 7; Florida PSC Comments at 7; Southwestern Bell Comments at 8; USTA Comments at 13 n.17; ALTS Comments at 9.

[12] AT&T Comments at 12.

[13] See 47 U.S.C. [[section]] 251(b)(2).

[14] CompTel Comments at 9.

[15] Id. at 15. It is critical that support not be collected or distributed in the form of carrier-to-carrier payments. If, as expected, prior distinctions between telecommunications service markets continue to lose their meaning, carrier-to-carrier payments inevitably would result in one provider subsidizing its competitor.

[16] AT&T Comments at 8-9; GTE Comments at 16-17; LDDS WorldCom Comments at 14-15; MCI Comments at 15-16; Pacific Telesis Comments at 16; U S West Comments at 15; USTA Comments at 24; NYNEX Comments at 24.

[17] See, e.g., AT&T Comments at 9; Citizens for a Sound Economy Foundation Comments at 5; Information Technology Association of America, et al., Comments at 16; GTE Comments at 17; NYNEX Comments at 24.

[18] Bell Atlantic Comments at 14.

[19] This method, however, makes listing a surcharge on end user bills problematic because each carrier's surcharge amount would vary, depending upon the level of its payments to other carriers. Clearly, the best solution is to reduce access charges to cost, and use a retail revenue surcharge for universal service funding.

[20] FCC, Universal Service Task Force, Preparation for Addressing Universal Service Issues: A Review of Current Interstate Support Mechanisms, 34 (hereinafter "Addressing Universal Service Issues").

[21] Id. at 41.

[22] See, e.g., AT&T Comments at 17; USTA Comments at 23; Pacific Telesis Comments at 22; GTE Comments at 22; BellSouth Comments at 13; NYNEX Comments at 16; Alabama-Mississippi Telephone Association Comments at 7; NCTA Comments at 13.

[23] LDDS WorldCom Comments at 18-19; see also Addressing Universal Service Issues at 38.

[24] See Addressing Universal Service Issues at 40-41.

[25] MCI Comments at 6.

[26] Ameritech Comments at 10-11; AT&T Comments at 14; U S West Comments at 12.

[27] MCI Comments at 10.

[28] 47 U.S.C. [[section]] 254(b)(3).

[29] CompTel Comments at 13-14.

[30] CompTel also agrees with Ameritech's recommendation that the subsidy provided to an eligible carrier should be the lesser amount yielded by (1) the cost measure minus the benchmark, or (2) the cost measure minus the carrier's actual rate. Ameritech Comments at 11. If a carrier is able, for whatever reason, to charge an above-benchmark rate in a particular region, universal service support payments are unnecessary for the amount by which the rate exceeds the benchmark.

[31] Pacific Telesis Comments at 18.

[32] CompTel Comments at 2.

[33] U S West Comments at 12.

[34] Southwestern Bell Comments at 23-24.

[35] BellSouth Comments at 7 n.10; NECA Comments at 10.

[36] Western Alliance Comments at 12.

[37] CompTel Comments at 16-17.

[38] BellSouth Comments at 6 n.8; Bell Atlantic Comments at 10; USTA Comments at 8- 9.

[39] 47 U.S.C. [[section]] 214(e)(1)(A).

[40] Similarly, there is no support in Section 214(e) for Bell Atlantic's argument that the "facilities" an eligible carrier uses as its own must be loop facilities. See Bell Atlantic Comments at 10.

[41] CompTel Comments at 16; see also AT&T Comments at 21; LDDS WorldCom Comments at 5; USTA Comments at 17 n.24.

[42] TRA Comments at 9-10.

[43] Id. at 8-9.

[44] See LDDS WorldCom Comments at 6.

[45] See Southwestern Bell Comments at 4-6; Florida PSC Comments at 12; USTA Comments at 18.

[46] AT&T Comments at 10-11.

[47] See AT&T Comments at 11 n.14.

[48] 47 U.S.C. [[section]] 271(d)(3)(c).

[49] CompTel Comments at 10-11.

[50] See, e.g., AT&T Comments at 8-9; GTE Comments at 4-5; MCI Comments at 4.

[51] AT&T Comments at 8 n.9.

[52] Implementation of the Local Competition Provisions in the Telecommunications Act of 1996, Notice of Proposed Rulemaking, CC Docket No. 96-98, FCC 96-182, at [[paragraph]] 28 (Apr. 19, 1996) (federal guidelines "minimize variations among states in implementing Congress' national telecommunications policy" and "expedite the transition to competition").