In the Matter of

Amendment of Part 36 of The
Commission's Rules and
Establishment of a Joint Board

CC Docket No. 96-45

REPLY COMMENTS OF THE CURTIS TELEPHONE CO., INC.

Curtis Telephone Company, Inc. (CTC), by counsel, hereby provides Reply Comments in the above captioned proceeding as follows:

CTC is a small. rural independent local exchange company providing telecommunications services in and around the agricultural community of Curtis, in the southwestern comer of Nebraska. The community of Curtis is very much dependent on the availability of affordable, quality telecommunications services. Among other things, telecommunications supports health, education, economic and social activities vitally needed by the community as well as provides a "lifeline" to and from the outside world. Without affordable, quality telecommunications services the community would surely endure atrophy and hardship. The availability of support from the Universal Service Fund (USF) is essential and contributes to life and well-being in Curtis.

CTC has become concerned that changes in the methodology and magnitude of USF undermine the well-being of its community. To this end, it has been following the Commission's various rulemaking proposals to "reform" USF and the path of new legislation through Congress. The Commission is now charged by Congress with the important task of implementing the Telecommunications Act of 1996 and, in particular, the various provisions of this new law that guide the Commission in this important undertaking. As a means to fulfill its responsibilities, CTC urges that the Commission give due consideration to the USF reform plan submitted by ITCS, Inc. as part of it Comments herein on April 12, 1996. That plan is known as the "Per Minute of Use Universal Service Plan." CTC believes that this plan warrants study and examination by the Commission. If the Commission finds that the plan is in furtherance of its goals and objectives, then the plan should be a matter of public notice and comment.

IN CONCLUSION, CTC urges the Commission study and analyze the above-referenced plan and to give it its due in furtherance of the public interest.

Respectfully Submitted,

David A. Irwin

Counsel for Curtis Telephone
Company, Inc. (CTC)
Irwin, Campbell & Tannenwald, P.C.
173O Rhode Island Ave., N.W.
Washington, D.C. 20036
(202) 728-0400

May 7, 1996