[2] See, e.g., Comments of NYNEX at 10, discussing the Benchmark Cost Model ("BCM") proposed by MCI, NYNEX, Sprint and US West. ("The BCM should only be used to calculate support amounts for price cap (i.e. large) LECs [because] such a model may not accurately portray the costs of a carrier that serves only a limited or smaller area, and thus could cause financial harm to small carriers.") See also MCI Comments at 11; Comments of US West, Inc. at 9; Comments of US West Communications, Inc. in CC Docket 80-286 at 26. The other, principal proxy cost model -- the one proposed by Pacific Telesis -- is proprietary and therefore cannot be adequately assessed at all. See, e.g., Comments of Teleport Communications Group, Inc. at 8.

[3] See, e.g., Comments of the Rural Utilities Service at 6 and 15; Comments of Southwestern Bell Telephone Company at 14-16; Comments of NYNEX, supra at 10. In fact, the exhaustive study described in Southwestern Bell's comments shows that the Benchmark Cost Model does not work for any LECs, large or small, rural or urban, but rather produces results that are comprehensively inaccurate. Comments of Southwestern Bell Telephone Company, supra at 14-16. While large, price-cap companies may average the effects of these systematic inaccuracies over a wide range of service environments, small companies have no such opportunity.

[4] At most, some proponents of proxies suggest that more refined models, so far undeveloped, might bring the range of error within acceptable limits. See, e.g., MCI Comments at 11; Comments of Teleport Communications Group, Inc. at 7-8. But until someone proposes, and convincingly demonstrates the accuracy of, such an improved proxy model, the universal service requirements of section 254 of the 1996 Act do not permit the use of proxies to calculate supports for smaller companies.

[5] 1996 Act, supra at [[section]]254(b)(3), 254(b)(5).

[6] Comments of Ad Hoc Telecommunications Users Committee ("Ad Hoc Comments") at 10; see also Comments of MFS Communications Company, Inc. at 18-19.

[7] Ad Hoc Comments, supra at 10.

[8] Id.

[9] See Comments of the Western Alliance at 10-12 and authorities cited therein.