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 SEPARATE  STATEMENT  OF  COMMISSIONER  MICHAEL  J.  COPPS 
 Re:  Federal-  State  Joint  Board  on  Universal  Service,  CC  Docket  No.  96-  45  (FCC  05-  46). 
 Today  the  Commission  largely  adopts  the  ETC  designation  recommendations  of  the  Federal-  State  Joint  Board  on  Universal  Service.  In  doing  so,  we  provide  a  more  rigorous  template  for  review  of  ETC 
 applications.  This  is  long  overdue,  and  I  am  pleased  to  support  it.  I  especially  am  encouraged  by  the  build-  out  plans,  reporting  requirements  and  annual  certifications  we  require  in  this  decision.  Collectively, 
 these  will  provide  this  Commission  and  our  state  counterparts  with  a  way  to  monitor  and  ensure  that  ETC  funding  truly  is  being  used  to  preserve  and  advance  universal  service. 


 As  promising  as  this  development  is,  much  more  work  needs  to  be  done  to  secure  the  long-  term  sustainability  of  universal  service.  As  ETC  designations  grow,  new  challenges  will  arise.  In  particular, 
 the  Commission  will  need  to  face  the  consequences  of  multiple  designations  in  high-  cost  areas  on  the  overall  size  of  the  fund.  In  addition,  key  questions  are  teed-  up  in  the  current  Joint  Board  referral 
 concerning  the  high-  cost  support  mechanism  and  the  level  of  support  made  available  to  multiple  ETCs.  While  we  don’t  resolve  these  issues  here,  they  are  an  important  part  of  the  larger  picture.  I  am  hopeful 
 that  today’s  decision  is  only  the  foundation  for  this  broader  discussion  and  that  in  the  near  future  we  will  build  on  the  efforts  to  increase  accountability  that  we  adopt  here. 
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