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 Federal  Communications  Commission  FCC  04J-  1 
 SEPARATE  STATEMENT  OF  COMMISSIONER  THOMAS  J.  DUNLEAVY,  NEW  YORK  STATE  PUBLIC  SERVICE  COMMISSION 
 Re:  Federal-  State  Joint  Board  on  Universal  Service,  Recommended  Decision 
 The  issues  referred  to  us  in  this  phase  of  this  proceeding  are  among  the  most  complex  and  contentious  we  have  been  asked  to  address.  They  go  to  the  heart  of  what  we 
 expect  a  universal  service  program  to  achieve  and  how  we  expect  it  to  interact  with  the  forces  of  a  competitive  market.  Although  this  Recommended  Decision  does  not  resolve 
 all  the  issues  before  us,  I  believe  the  recommendations  we  make  here  today  will  help  sustain  the  federal  universal  service  program,  enabling  it  to  more  effectively  achieve  our 
 dual  goals  of  fostering  competition  while  preserving  universal  service.  I  support  this  Recommended  Decision  as  a  reasonable  step  in  the  right  direction. 


 Perhaps  the  most  significant  recommendation  we  make  here  today  is  to  provide  federal  high  cost  support  only  for  a  subscriber's  or  household's  primary  connection  to  the 
 telephone  network.  I  believe  this  recommendation  is  entirely  consistent  with  the  fundamental  purpose  of  the  federal  universal  service  program  –  ensuring  that  all  homes 
 and  businesses  can  affordably  connect  to  the  rest  of  the  world.  When  the  Telecommunications  Act  of  1996  was  being  crafted,  I  doubt  many  people  anticipated  that 
 in  less  than  a  decade  most  households  would  have  both  a  wireline  and  a  wireless  phone  and  that  many  would  have  multiple  wireless  phones.  I  am  convinced  that,  however  much 
 we  might  like  to,  we  simply  cannot  sustain  a  universal  service  program  that  provides  support  to  two,  three,  four  or  more  phones  in  most  households.  At  the  same  time,  rules 
 that  would  effectively  preclude  support  to  wireless  services  would  not  be  competitively  or  technologically  neutral  and  might  artificially  slow  the  deployment  of  desirable  and 
 potentially  less  costly  services  to  high  cost  areas.  While  implementation  of  our  recommendation  to  support  only  primary  lines  will  no  doubt  involve  some  administrative 
 complexities,  I  am  confident  that  reasonable  solutions  will  be  found  through  further  development  of  the  record,  as  we  here  recommend.  I  also  am  confident  that  resolution  of 
 those  challenges  will  place  far  fewer  demands  on  the  high  cost  support  mechanism  than  will  continuing  to  support  multiple  lines  per  household. 


 That  said,  I  am  keenly  aware  that  our  primary  line  proposal  could  significantly  affect  the  support  currently  provided  to  existing  eligible  telecommunications  carriers.  No 
 rule  should  be  thought  to  be  permanent,  yet  when  changes  are  made  reasonable  efforts  should  be  made  on  a  transitional  basis  to  mitigate  sudden  and  severe  negative 
 consequences.  I  am  pleased  that  our  Recommended  Decision  recognizes  this  by  offering  several  alternative  proposals  for  further  comment.  Without  expressing  a  preference  for 
 any  of  the  alternatives,  I  would  emphasize  that  no  mitigation  effort  can  be  expected  to  live  on  in  perpetuity,  nor  should  one  be  used  as  a  means  to  forestall  competition  in  any 
 area.  Congress  was  quite  clear;  it  intended  to  open  all  telecommunications  markets  to  competition,  not  just  markets  in  low  cost  or  urban  areas. 


 It  is  a  testament  to  the  dedication  and  professionalism  of  my  Joint  Board  colleagues  that  we  are  able  to  suggest  some  significant  changes  to  improve  the  federal 
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 Federal  Communications  Commission  FCC  04J-  1 
 universal  service  program,  even  as  we  continue  to  seek  a  fuller  record  on  several  issues.  The  state  and  federal  staffs  supporting  this  Joint  Board  once  again  have  done  an 
 exemplary  job  helping  us  to  understand  the  issues  and  our  options  and  reducing  our  thoughts  to  writing.  I  offer  them  all  my  sincere  appreciation. 
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