Last year marked the tenth anniversary of the Telecommunications Act (“the Act”). Since its passage, the only thing that has remained constant in the communications industry is change—the development of new technologies, industry consolidation and convergence, product bundling, etc. Th ese radical transformations have resulted in recent efforts to reform communications laws and policies. One of the central issues of the debate on communications policy has been the reform of “universal service,” a policy that stands for the principle that all Americans should have access to quality telephone service at reasonable rates regardless of where they live and their level of income....