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 SEPARATE  STATEMENT  OF  COMMISSIONER  KATHLEEN  Q.  ABERNATHY  Re:  Federal  State  Joint  Board  on  Universal  Service,  CC  Docket  No.  96-  45  (adopted 
 October  16,  2003) 


 Today  we  bring  closure  to  the  complex  set  of  rules  that  allocate  universal  service  funds  to  non-  rural  carriers.  These  companies  are  the  largest  carriers  providing 
 telecommunications  service  across  the  United  States.  Although  most  of  the  high  cost  loop  support  is  directed  to  smaller  rural  carriers  (well-  over  90%),  the  non-  rural  carriers 
 are  also  a  critical  component  of  the  success  of  USF  in  America.  In  some  states,  for  example,  the  non-  rural  carrier  may  be  the  primary  provider  of  communications  service 
 for  rural  Americans.  Given  this  critical  position,  the  USF  Joint  Board  and  the  FCC  were  dedicated  to  crafting  high-  cost  support  rules  that  would  ensure  comparable  rural  and 
 urban  rates  for  areas  served  by  the  non-  rural  carriers. 
 Today’s  order  reflects  that  effort.  First,  we  adopt  a  more  precise  definition  of  the  statutory  terms  “sufficient”  and  “reasonably  comparable”  for  purposes  of  the  non-  rural 
 support  mechanism.  Second,  we  adopt  a  methodology  for  setting  a  national  average  cost  per  line  benchmark.  Third,  we  have  created  an  expanded  annual  certification  process, 
 which  provides  an  inducement  to  states  to  achieve  reasonably  comparable  rates.  This  mandatory  review  process  encourages  each  state  to  examine  whether  its  policies  are 
 achieving  rate  comparability  and  if  not,  to  take  such  action  as  necessary  to  do  so.  It  also  enables  the  Commission  to  evaluate  whether  the  non-  rural  mechanism  is  achieving  the 
 goal  of  reasonable  comparability  among  states,  while  placing  primary  responsibility  on  the  states  and  giving  each  state  the  flexibility  to  regulate  basic  rates  and  services. 


 I  believe  the  modifications  we  are  making  to  our  Universal  Service  requirements  address  the  concerns  outlined  by  the  Tenth  Circuit.  The  order  also  furthers  the  goals  of 
 the  Communications  Act  by  ensuring  that  there  are  reasonably  comparable  urban  and  rural  rates  for  all  customers  served  by  non-  rural  carriers. 
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