[1] It is front page news that local phone companies around the country already believe that they will need to raise local rates by $10 per month to fund embedded technology in the event that access fees are reduced. Mike Mills, Phone Firms Seek Higher Local , Washington Post, May 7, 1996, at A1. Increasing local rates would be unnecessary for carriers using ultra-efficient network technology like WinStar.

[2] In Paragraph 16 of the NPRM, the Commission proposes providing universal service support for: "(1) voice grade access to the public switched network, with the ability to place and receive calls; (2) touch-tone; (3) single party service; (4) access to emergency services (911); and (5) access to operator services."

[3] Many other commenters supported the Commission adopting a technology-neutral paradigm. Comments of Alliance for Public Technology, at 13-14; Comments of Apple Computer, at 3; Comments of State of California, 10-12; Comments of Citizens for a Sound Economy, at 6-7; Comments of Council on Competitiveness, at 4; Comments of LDDS WorldCom, at 4-7; Comments of MFS, at 8.

[4] The Rural Electrification Act requires applicants for federal electrification loans to demonstrate a minimum broadband capability of 1 Mb/second. 7 U.S.C. [[section]] 935 (d)(3)(b) (1994). 7 U.S.C. [[section]]\~935 (1994).

[5] WinStar funded the development of 1 Mb/second broadband capability without using any kind of universal service subsidies. It would be inappropriate for incumbent carriers to fund their build-out of broadband capability with federal subsidies.