As a competing provider of local exchange service, TW Comm is committed both to supporting and expanding the availability of affordable basic telephone service in all parts of the nation and to all citizens. In order to meet the goals enumerated in Sections 254 and 214 of the 1996 Act, however, the current mechanisms for funding universal service must be revised. Put simply, the current system relies too heavily on local exchange carrier ("LEC") reported costs. These costs are inflated and do not portray the actual costs necessary to provide local exchange services with any accuracy. To determine universal service support for high cost areas, the Commission must adopt an objective approach. The primary focus of such an objective approach should be the user, rather than the service provider. Further, an objective approach will ensure that the approach actually supports and promotes universal affordability of basic telephone services and does not merely provide one more opportunity for financial assistance to support LEC revenue requirements.
In determining whether a particular area qualifies for high cost support, an affordability benchmark should be determined and not until local rates exceed the benchmark should an area be deemed eligible for support. In determining the amount of support needed to efficiently serve the area, the Commission should implement a cost proxy model to calculate the costs of serving the area. Once the costs of serving an area have been determined, a competitive bid should be conducted to ensure that services are being provided to customers in the most efficient manner and at the least possible cost.
The responsibility of funding universal services must be equitably allocated. However, before this can be accomplished the non-targeted support mechanisms that currently exist must be eliminated. To the extent targeted support is necessary, it should be based upon a value added assessment of all industry participants.
TW Comm supports providing schools, libraries and health care providers with access to basic and advanced telecommunications services; however, answers to the questions raised in this proceeding cannot be properly answered until more information has been gathered. The Commission should thus initiate a separate Notice of Inquiry proceeding to acquire the requisite information that will enable parties to properly and informatively comment on these very important issues.