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 SEPARATE  STATEMENT  OF 
 COMMISSIONER  KEVIN  J  .  MARTIN 


 Re:  2000  Biennial  Regulatory  Review  –  Comprehensive  Review  of  the  Accounting 
 Requirements  and  ARMIS  Reporting  Requirements  for  Incumbent  Local  Exchange 
 Carriers:  Phase  2,  Report  and  Order,  CC  Docket  No.  00-  199 


 This  item  is  a  next  step  in  reducing  regulatory  burdens  relating  to  our  accounting 
 and  reporting  requirements.  The  Commission’s  accounting  and  reporting  rules  impose 
 real  costs  on  incumbent  local  exchange  carriers.  As  such,  the  Commission  needs  to 
 ensure  that  each  of  these  rules  is  truly  necessary  and  that  the  benefits  of  retaining  a  rule 
 outweigh  its  costs.  The  Commission  has  endeavored  to  do  so  here  and  has  eliminated  a 
 large  number  of  unnecessary  rules. 


 In  addition,  the  Commission  has  begun  a  further  proceeding  to  address  additional 
 streamlining  of  these  rules.  The  Commission  concludes  that  many  of  its  rules—  for 
 example  the  detailed  requirements  for  continuing  property  records—  serve  no,  or  only  a 
 limited,  federal  regulatory  purpose  and  are  burdensome.  We  decided  not  to  eliminate 
 such  requirements  immediately—  and,  indeed,  agreed  to  add  several  new  requirements— 
 out  of  deference  to  the  State  commissions.  Many  of  these  commissions  currently  rely  on 
 our  rules  to  ensure  that  information  is  available  to  them.  They  assert  it  would  cause  them 
 hardship  were  we  to  cease  this  function  immediately. 


 While  I  believe  we  should—  and  we  have—  worked  hard  to  accommodate  our 
 State  colleagues’  concerns,  I  am  reluctant  to  continue  in  perpetuity  federal  rules  that 
 serve  only  State  needs.  Rather,  as  we  make  clear  in  the  further  notice,  the  Commission 
 must,  at  some  point  in  the  future,  eliminate  requirements  that  no  longer  serve  specific 
 federal  needs.  I  also  am  hopeful  that  the  Commission  will  soon  be  able  to  eliminate  a 
 range  of  other  requirements  that  serve  only  limited  federal  purposes  and  are  unduly 
 burdensome,  especially  in  light  of  alternative  means  to  gather  information. 


 I  thus  look  forward  to  engaging  in  a  dialogue  with  the  States  on  how  we  can 
 develop  a  transition  in  which  States  can  undertake  greater  responsibility  for  collecting  the 
 information  they  need.  In  conducting  this  dialogue  and  developing  such  a  glide  path,  I 
 urge  all  parties  to  consider  whether  we  truly  need  much  of  the  information  that  we 
 collect.  Moreover,  where  this  information  is  needed,  we  should  examine  alternative,  less 
 burdensome  means  of  collecting  it.  It  is  imperative  that  we  move  away  from  our  narrow 
 focus  on  incumbent  local  exchange  carriers  as  the  sole  source  of  this  information.  As 
 competition  continues  to  develop  and  formerly  distinct  sectors  of  the  communications 
 industry  continue  to  converge,  remaining  accounting  and  reporting  requirements 
 generally  should  fall  on  all  classes  of  competitors  equally. 
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