Re: NTIA Reply Comments filed in CC Docket Nos. 95-115 and 96-45, Amendment of the Commission's Rules and Regulations to Increase Subscribership and Usage of the Public Switched Network and Federal-State Joint Board on Universal Service, respectively

A. SUBSCRIBERSHIP [Reply Comments filed March 29, 1996, Dkt. 95-115]

• The Commission should establish a National Subscribership Goal so that by the year 2000, within each state, average telephone penetration rates for all households, including certain designated economic, racial, ethnic, and geographic categories, will be at or above the national average that exists as of November 1996. [See Reply Comments at 4-8]
  
  
• States should have broad latitude to implement policies and programs designed to achieve the National Subscribership Goal (such as a ban on the disconnection of local service for nonpayment of long distance charges). If the national goal has not been achieved by the year 2000, the Commission should assess whether Federal action is needed to accomplish that goal. [See Reply Comments at 8-10]

B. UNIVERSAL SERVICE POLICIES [Reply Comments filed June 12, 1996, Dkt. 96-45]

• The Federally-defined universal service package should ensure the provision a single voice grade line to residential customers. The basic package should also include: touch tone dialing and a reasonable amount of free usage; access to toll, emergency, and relay services; access to repair services and directory and operator assistance; and privacy protections, including caller ID with blocking options. [See Reply Comments at 6-9]
  
  
• The Commission should convene a Joint Board to assess the adequacy of the Federally-defined universal service package every three years. The Commission should consider instituting more frequent reviews in response to petitions from interested parties. [See Reply Comments at 8 n.18]
  
  
• Low income households meeting a State-determined means test should be eligible for support from the Federal universal service fund (up to the full amount of the subscriber line charge), if the relevant State provides reductions in intrastate charges that equal or exceed 25 percent of the Federal support. [See Reply Comments at 12-15]
  
  
• Eligible companies whose costs exceed 130 percent of the national average should be entitled to receive, for each customer served, high cost support equivalent to the difference between the companies' actual costs and 130 percent of the national average. Company costs should be determined by some objective benchmark. [See Reply Comments at 15-19]
  
  
• States ought to have latitude to establish their own competitively neutral mechanisms for furnishing low income and high cost support. States should also be allowed to create transitional support mechanisms to mitigate any "rate shock" caused by the alignment of prices with underlying costs. [See Reply Comments at 19-21]
  
  
• All providers of interstate telecommunications services should contribute to the Federal universal service fund, based on a percentage of their interstate revenues (less payments for interstate telecommunications services purchased from companies that also contribute to the Federal fund). [See Reply Comments at 22-25]
  
  
• The Commission should construe the term "eligible telecommunications carrier" (ETC) to maximize the number of firms eligible to receive Federal universal service support, thus encouraging competition. Federal support should be given to ETCs based solely on the number of customers served, thereby making it easier for ETCs to compete for customers. [See Reply Comments at 25-28]

Please see also: NTIA's Further Comments in CC Docket 96-45 filed October 10, 1996, describing the Administration's E-rate proposal.