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 STATEMENT  OF  COMMISSIONER  MICHAEL  J.  COPPS, 
 CONCURRING 
 Re:  AT&  T  Petition  for  Declaratory  Ruling  Regarding  Enhanced  Prepaid  Calling  Card  Services;  Regulation  of  Prepaid  Calling  Card  Services,  Order  and  Notice  of 
 Proposed  Rulemaking  (WC  Docket  No.  03-  133) 
 By  law,  this  Commission  has  a  duty  to  preserve  and  advance  universal  service.  In  some  ways  we  live  up  to  that  charge  today.  But  in  others  our  analysis  falls  short.  We  clarify  in  this 
 item  that  AT&  T  calling  card  services  that  include  incidental  announcements  or  advertisements  are  basic  telecommunications  services,  subject  to  universal  service  obligations.  This  sets  straight 
 a  messy  situation  and  I  support  the  result. 
 Still,  I  am  concerned  with  the  backward-  looking  nature  of  our  decision.  By  starting  a  Notice  of  Proposed  Rulemaking,  the  Commission  suggests  that  going  forward  the  boundary 
 between  calling  cards  subject  to  universal  service  and  those  that  are  not  is  whether  they  feature  an  automated  voice  that  coos  on  the  line  “press  1  for  more  information.”  There  may  be  a  bright  line 
 out  there  between  services  subject  to  regulatory  authority  and  those  that  are  not.  But  I  doubt  this  is  it.  And  by  initiating  a  proceeding  based  on  this  distinction,  the  Commission  all  but  ensures  that 
 calling  card  confusion  from  the  past  is  perpetuated  in  the  future.  Because  I  believe  we  have  deeper  analytical  duties  when  it  comes  to  universal  service,  I  choose  to  concur. 
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