Federal Communications Commission FCC 07-185
STATEMENT OF
COMMISSIONER ROBERT M. McDOWELL
Re: Applications of ALLTEL Corporation, Transferor, and Atlantis Holdings LLC, Transferee for 
Consent To Transfer Control of Licenses, Leases and Authorizations, WT Docket No. 07-128.
I am pleased to support the transfer of control of ALLTEL Corporation given the significant 
benefits to wireless consumers and the citizens in Arkansas.  However, I am concerned regarding the 
“voluntary” conditions agreed to by the applicants.  Imposing conditions pertaining to high cost universal 
service support and Enhanced 911 (E911) deployment are not merger specific, are unnecessary at this 
time, and may prejudice ongoing Commission deliberations.  
Today’s Order conditions approval of the transaction by capping ALLTEL’s high cost universal 
service support at June 2007 levels on an annualized basis for an indeterminate period.  The condition 
also provides ALLTEL a “limited exception”:  ALLTEL will not be subject to the cap if it files cost data 
showing its own per-line costs as an alternative to the capped funding level, and demonstrates immediate
compliance with the E911 Public Safety Answering Point (PSAP) location accuracy standard.      
With respect to universal service, today’s Order expressly states that the Commission has not yet 
adopted the Joint Board’s recommendation regarding an interim cap on high cost universal service 
funding for competitive eligible telecommunications carriers (ETCs).  ETC support is not raised or 
discussed in the record of this proceeding.  Furthermore, the condition prejudices the Commission’s open 
docket considering universal service support distribution.  I also question whether we have thought about 
how the actions today may skew future treatment of similarly-situated parties.  
With respect to E911, given its citation only to an FCC News Release, today’s Order makes plain 
that the Commission has yet to release its September 11, 2007, E911 Order.  There the Commission set a 
deadline of September 11, 2012, for wireless carriers to satisfy E911 accuracy as measured at the PSAP 
level despite considerable debate as to whether the mandate has adequate support within the E911 record.  
E911 is not discussed at all in this proceeding.  And, just as with universal service, introducing E911 
mandates into this distinct proceeding will surely impact future consideration of similarly-situated parties.  
The conditions imposed today raise more questions than they answer.  Given the ongoing nature 
of the universal service and E911 proceedings, I wonder whether this is an attempt to bind future 
Commission action, and dictate or bind government policy.