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 STATEMENT  OF  COMMISSIONER  MICHAEL  J.  COPPS, 
 APPROVING  IN  PART,  DISSENTING  IN  PART 
 Re:  Presubscribed  Interexchange  Carrier  Charges,  Report  and  Order  (CC  Docket  No.  02-  53) 


 The  Commission’s  $5  safe  harbor  for  PIC  change  charges  has  been  on  our  books  for  two  decades.  The  $5  charge  is  a  relic  from  the  early  days  of  divestiture.  So  I 
 welcome  the  opportunity  this  proceeding  affords  to  bring  the  PIC  change  charge  into  the  modern  era  of  telecommunications.  This  is  especially  important  because  these  charges 
 can  end  up  on  consumer  bills  whenever  end  users  switch  long  distance  providers. 
 But  I  think  today’s  decision  may  miss  the  mark.  While  the  Order  lowers  the  mechanized  threshold  to  $1.25,  it  raises  the  manual  threshold  to  $5.50.  To  figure  out  if 
 this  is  good  or  bad  for  consumers,  it  is  important  to  determine  how  many  changes  are  processed  mechanically  and  how  many  are  processed  manually.  Yet  we  don’t  analyze 
 this  thoroughly  in  today’s  decision.  There  is  record  evidence  seeming  to  show  that  while  as  few  as  21%  of  PIC  changes  are  mechanized,  as  many  as  79%  are  manual.  1  This  means 
 that  while  the  benefit  of  a  lower  PIC  change  charge  is  enjoyed  by  a  few,  the  burden  of  a  higher  charge  could  be  imposed  on  the  many.  And  no  amount  of  discussion  about  net 
 benefits  or  changed  incentives  can  mask  the  fact  that  this  Order  could  subject  the  majority  of  end-  users  to  increased  charges.  As  a  result,  I  support  today’s  item  and  our 
 effort  to  reduce  charges  for  mechanized  changes,  but  respectfully  dissent  from  its  conclusions  with  respect  to  manual  charges. 


 1  See  Letter  from  Mary  L.  Henze,  Assistant  Vice  President,  BellSouth  D.  C.,  Inc.,  Attachment  at  3  (filed 
 February  1,  2005);  see  also  Letter  from  Richard  T.  Ellis,  Executive  Director,  Verizon  (filed  February  8,  2005);  Letter  from  Toni  Acton,  Associate  Director,  SBC  Services  Inc.,  Attachment  (filed  February  7, 


 2005). 
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