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 Federal  Communications  Commission  FCC  04-  149 
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 STATEMENT  OF  COMMISSIONER  KEVIN  J.  MARTIN, 
 APPROVING  IN  PART,  CONCURRING  IN  PART 
 Re:  Federal  State  Joint  Conference  on  Accounting  Issues,  WC  Docket  02-  269;  2000  Biennial  Regulatory  Review,  CC  Docket  No.  00-  199;  Jurisdictional  Separations  Reform  and  Referral  to 
 the  Federal-  State  Joint  Board,  CC  Docket  No.  80-  286;  and  Local  Competition  and  Broadband  Reporting,  CC  Docket  No.  99-  301 


 Today,  the  Commission  acts  on  recommendations  submitted  by  the  Federal-  State  Conference  on  Accounting.  This  Order  only  grants  some  of  the  Joint  Conference’s  recommendations,  I  approve  in  part 
 and  concur  in  part  in  this  item. 
 This  Order  reinstates  several  Part  32  Accounts  that  provide  states  with  the  critical  accounting  information  they  need.  The  Order  also  requires  ILECs  to  maintain  subsidiary  records  categories  for 
 unbundled  network  element  revenues,  resale  revenues,  reciprocal  compensation  revenues  and  other  interconnection  revenues  in  accounts  in  which  these  revenues  are  currently  recorded.  Although  this  item 
 does  not  go  as  far  as  requiring  companies  to  maintain  this  information  in  Part  32,  this  item  does  require  ILECs  to  make  all  this  data  available  to  the  states  and  to  this  Commission  upon  request.  I  am  pleased  to 
 see  the  Commission  listened  to  the  Joint  Conference’s  call  for  the  need  to  have  access  to  this  crucial  accounting  information. 


 As  I  said  when  the  Joint  Conference  filed  its  recommendation  with  the  FCC,  I  was  concerned  that  the  costs  associated  with  providing  information  related  to  certain  affiliate  transactions  might  outweigh  the 
 benefits  of  getting  that  information.  I  feel  the  Commission  could  have  provided  a  tangible  benefit  to  state  regulators  by  approving  some  of  the  crucial  affiliate  transactions  recommendations  without  unduly 
 burdening  the  ILECs  that  would  have  to  provide  this  information.  For  this  reason,  I  must  concur  with  this  part  of  today’s  Order. 
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