2 In the Matter of Federal-State Joint Board on Universal Service, Notice of Proposed Rulemaking and Order Establishing Joint Board, CC Docket No. 96-45, FCC 96-93, released March 8, 1996.
]3 See, e.g., MFS at p. 16; Teleport at p. 6; Bell Atlantic at p. 7; Frontier at p. 3; GTE at p. 5; Georgia PSC at p. 7.
4 See, e.g., AT&T at p. ii; LDDS WorldCom at pp. 7-8; MCI at p. ii; Sprint at p. 6; Time Warner at p. 4; US West at p. 7; USTA at p. ii; Alaska PSC at p. 13; California PUC at p. 6; New York DPS at p. 16; Illinois Commerce Commission at pp. 2-5.
5 See, e.g., NYNEX at p. 11-12; AT&T at p. (ii); MCI at p. (ii); MFS at p.16; Sprint at p. 6; TCG at p. 6; USTA at p. (I); Colorado PUC at pp. 2-4; Florida PSC at pp. 5-7; Missouri PSC at pp.4-6.
6 See AT&T at p. 21; Sprint at pp. 8-9; California PUC at p. 13; Florida PSC at p. 13; Missouri PSC at p. 9; Pennsylvania at p. 23. To the extent that an eligible carrier provided universal service through resale, the underlying carrier that provided the resold services should receive the universal service support funds.
7 See, e.g., Georgia PSC at p. 7; NYNEX at pp. 12-13.
8 See Section 254(c). Wireless services are subscribed to by only about 21% of the nation's households. See The New York Times, Section 4, Week in Review, The Great Unplugged Masses confront the Future, April 22, 1996.
9 See A Policy Maker's Guide to Deregulating Telecommunications Part 3: Solving the Local VS. long-distance Dilemma, By Adam D. Thierer; The Heritage Foundation February 21, 1993, p. 13.
10 See, e.g., NECA at p. 7; GVNW at pp. 10-11; John Staurulakis at p. 7; Rural Telephone Coalition at p. 15; Bell Atlantic at p. 13.
12 See Sections 61.45, 69.4, 69.105, 69.603, and 69.502
13 See 47 U.S.C. Sections 254(b)(5), 254(b)(4), and 254(e).
14 With this support, the small LECs could avoid increasing their state rates when DEM weighting was discontinued.
15 Elimination of LTS would cause the small LECs' CCL rates to increase by $446 million, while elimination of DEM weighting would reduce their Local Switching rates by $275 million, for a net increase of $171 million. Elimination of DEM weighting would reduce the large LECs' interstate switched access rates by $47 million. That amount could be recovered through a proxy model such as the Benchmark Cost Model, which includes switching costs.
16 See AT&T at Appendix A, p. 1; LDDS WorldCom at p. 10; MCI at p. ii; Sprint at p. 8; TCG at p. 7; US West at p. 8; Florida PSC at pp. 9-10; Pennsylvania PUC at pp. 17-18; Wyoming PSC at p. 17.
17 See Wyoming PSC at p. 7; Sprint at p. 11.
18 See NYNEX at p. 10; Time Warner at p. 9.
19 See Sprint at p. 12. See also Reply Comments of the NYNEX Telephone Companies, CC Docket 80-286, filed November 9, 1995.
21 See In the Matter of Implementation of the Local Competition Provisions in the Telecommunications Act of 1996, Notice of Proposed Rulemaking, CC Docket No. 96-98, FCC 96-182, released April 19, 1996, para. 137.
23 See Reply Comments of the NYNEX Telephone Companies, CC Docket 80-286, filed November 9, 1995, pp. 10-11.
24 See Alaska PSC at p. 8; Bell Atlantic at p. 11; Florida PSC at pp. 21-22; Georgia PSC at pp. 11-13; Indiana Utility Regulation Commission at pp. 8-10; New York DPS at p. 8; Pennsylvania PUC at p. 23; Washington Utilities and Transportation Commission at pp. 18-20.
25 See AT&T at p. 16; MFS at p. 2; Sprint at p. 20; Time Warner at p. 20; Ameritech at p. 21; BellSouth at p. 2; GTE at p. 15; Southwestern at p. (I); USTA at p. (ii); California at p. 20.
26 Some State PUCs have argued that any effort to eliminate the CCL charge is likely to infringe upon the State's authority to advance universal service under Section 254(f) of the Act. See, e.g., Indiana Utility Regulation Commission at p 8-10.
28 See, e.g., BellSouth at p. 2.
29 See NYNEX at pp. 3-8; see also Missouri PSC at pp. 20-21; New York DPS at p. 4.
31 See AT&T at p. 7; NYNEX at pp. 23-24; NECA at pp. 17-18; LDDS WorldCom at pp. 3-4; MCI at p. 12; MFS at pp. 23-24; Sprint at p. 4; Ameritech at p. 23; BellSouth at p. 15; Cincinnati Bell at p. 14-15; Southwestern Bell at p. (I); US West at p. 16; USTA at p. (ii); GVNW at p. 4; California PUC at p. 21; Colorado PUC at p. 6; Florida PSC at p. 25; Idaho PSC at p. 17; Maine PUC at p. 2; NECA at pp. 17-19; New York DPS at pp. 9-10; Wyoming PSC at pp. 4-5.
32 See, e.g., Southwestern Bell at p. (I); USTA at p. (I); Wyoming PSC at pp. 4-5; GVNW at p. 4.
34 See AT&T at p. 7; Sprint at p. 4, GTE at p. 17.
35 New York DPS at p. 9; see also California PUC at p. 21.
37 While NYNEX proposes that the universal service fund exclude access revenues and reseller revenues, these minor differences from the TRS model would not make the surcharge any more difficult to administer.
38 TCG at pp. 13-14; See also MFS at p. 16.
39 See Exhibit 1. The gross interstate revenues are $86.4 billion; See In the Matter of Telecommunications Relay Services, and the Americans with Disabilities Act of 1990; CC Docket No. 90-571, released December 14, 1995.
40 See, e.g., U.S. Distance Learning Assoc. at pp. 6-11; New York State Education Department at p. 10; National School Boards Association at p. 14; Illinois Board of Education at pp. 6-7.
41 See, e.g., National School Boards Association at p. 11.
42 See, e.g., American Library Association at p. 14; Illinois Board of Education at pp. 8-9; Sailor, A Maryland Library Project at p. 18.
43 On line 11, base case retail revenues are reduced by the sum of lines 1 through 5, since those amounts would be recovered through the universal service surcharge, rather than through the carriers' retail rates. Price cap LECs currently receive $325 million of funding from the USF. The NYNEX proposal assumes that any additional funding that exceeded the old funding would be reflected in a reduction in interstate rates. Retail revenues are not adjusted for funding of schools and libraries, since these are new funds that are not currently included in the carriers' retail rates.
44 This surcharge is based on the assumption that funding for schools and libraries is introduced in 1997; after the initial five year period, the ongoing cost for schools is assumed to be at a level of $720 million, and for libraries at a level of $78 million. At that point, the surcharge would drop to 3.40%. See Exhibit 1.
45 See NYNEX Comments in CC Docket 96-45, at p. 21-23, and Exhibit D.
46 The Council notes that the cost model is intended to serve only as a starting point for determining the cost of connecting all public libraries. Existing raw data for determining levels of technology to public libraries is not as robust as the data available for public schools. The Council advises that additional research is required for a more accurate estimation of costs. For a description of the library model and its costs, see U.S. Advisory Council on the National Information Infrastructure, KickStart Initiative (1996), p. 94-98.
47 The Council notes that public libraries face access and service provision problems that differ from those faced by schools. Bandwidth capacity and other connectivity issues can result in substantial differences in the costs of connecting urban and rural libraries. In addition, public libraries have already made some progress toward providing Internet and other related services to the public, which means that the overall costs presented in the model may be overestimated.
48 In connection with schools, McKinsey notes that some may find it more cost-effective to implement 5 ISDN lines instead of 10 POTS lines. The 5 ISDN lines, like the 10 POTS lines, permit 10 concurrent users--but with double the performance capability and the ability to handle video. Depending the tariff structure in that area, the 5-10 year cost for this additional capability could be fairly minimal--in fact, the extra $4,000 in installation charges above that for telephone lines is likely to be quickly recouped in lower usage charges.
49 For Content/Resource Development, the Council uses the Carl UnCover estimate of $5,000 for standard access via the Internet and 500 articles downloaded at a cost of $6.50 each, and notes there may be additional software and service required by individual public libraries, each adding an additional cost to this category.