[1] MobileMedia, the parent company of MobileMedia Paging, Inc. and Mobile Communications Corporation of America, holds narrowband paging licenses throughout the common carrier and private carrier bands. In addition, the company has two nationwide one-way wireless networks, and two nationwide narrowband PCS licenses.

[2] In the Matter of Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Notice of Proposed Rulemaking and Order Establishing Joint Board, FCC 96-93 (rel. Mar. 8, 1996) ("NPRM").

[3] The terms "one-way paging" and "narrowband paging" are used interchangeably herein.

[4] 47 U.S.C. [[section]] 332(c)(3).

[5] See Comments of MobileMedia at 4-6; see also Comments of Reed Smith Shaw & McClay at 5 ("Section 332(c)(3) of the Act leaves authority in the states to regulate intrastate universal service responsibilities for CMRS carriers providing intrastate services within their jurisdiction only to the extent the CMRS services can substitute for land line telephone exchange service for a substantial portion of the communications within such a state."); the Personal Communications Industry Association ("PCIA") at 9-11; AirTouch Communications, Inc. ("AirTouch") at 3-6; the Cellular Telecommunications Industry Association ("CTIA") at 4-8.

[6] See, e.g. Comments of Reed Smith Shaw & McClay at 6.

[7] See Comments of Teleport Communications Group, Inc. at 13.

[8] See Comments of Metricom, Inc. at 3.

[9] Telecommunications Industry Revenue: TRS Fund Worksheet Data, Table 2 (Feb. 1996).

[10] Spring 1996 Common Carrier Competition Report (Apr. 10, 1996) at 6. By comparison, cellular carriers alone accounted for 7%. Id.

[11] It is noteworthy that the Commission has already acknowledged that the revenues of one participant in this group -- competitive access providers -- are de minimis: "[e]ven though competitive access provider (CAP) revenues have gone to approximately $1.15 billion in 1995, they still represent a de minimis portion of the market." In the Matter of Implementation of the Local Competition Provisions in the Telecommunications Act, Notice of Proposed Rulemaking, CC Docket No. 96-98, (FCC 96-182) (rel. Apr. 19. 1996) at n.13.

[12] See, e.g., Comments of Reed, Smith, Shaw & McClay at 10-11 (wireless services are not comparable or a substitute for basic service and should be exempted from support of universal services).

[13] NPRM at [[paragraph]][[paragraph]] 15-22. In fact, several commenters argue that the services which should be deemed "core" are dial-tone and access services only. See Comments of Sprint at 7-8; BellSouth at 5-6; LCI International at 3; Bell Atlantic at 7-8; Ameritech at 6-7. Brite Voice Systems, Inc. is the only party to specifically address paging. Brite Voice merely suggests, however, that two-way paging be eligible for universal support. See Comments of Brite Voice Systems, Inc. at 5.