Federal Communications Commission FCC 07-43
STATEMENT OF
COMMISSIONER MICHAEL J. COPPS, 
APPROVING IN PART, DISSENTING IN PART
Re:  In the Matter of Verizon Communications, Inc. and América Móvil, S.A. DE C.V., 
Application for Authority to Transfer Control of Telecomunicaciones de Puerto 
Rico, Inc., WT Docket No. 06-113
The lens by which I view all transactions is the one mandated by Congress: any 
acquisition must serve the public interest, convenience and necessity. There is certainly 
much that needs to be done to help consumers in Puerto Rico. To say the situation in 
Puerto Rico for basic telephone service is dreadful puts it mildly. The penetration rate for 
basic telephone service is more than 30 percentage points lower than the national average 
of 94%. By some accounts there are approximately 200 communities in the most rural 
parts of Puerto Rico that don’t have any telephone service. This is to say nothing of 
access to broadband. With this as backdrop, there is plenty of opportunity for the 
Applicant to demonstrate that its new ownership will markedly change the situation.
The Applicant’s commitment to invest $1 billion over five years to improve 
telephone service in Puerto Rico is a promising start. This commitment, 
comprehensively implemented, can be a real agent for positive change. But important 
questions remain. Will this commitment lead to desperately-needed investment in 
wireline services? Will it deliver broadband deployment to rural areas? Will it translate 
into significantly wider penetration of services and ensure the quality of those services?
Will the FCC follow through with the kind of rigorous monitoring and auditing to ensure 
implementation of the commitment? The people of Puerto Rico have been waiting for 
commitments to be implemented for a long time. This transaction must be made to serve 
these people.
Our Order requires that the Applicant annually provide the Commission 
quantifiable and verifiable data on its progress in deploying basic telephone and 
broadband services throughout Puerto Rico. A year from now we will take stock of 
where we are and I expect the Commission to be vigilant in keeping the Applicant’s feet 
to the fire. 
The stakes are high here. Many parties on record, including labor leaders, local 
and federal officials, local regulators, and competitive carriers urged the Commission not 
to approve the merger without a significant commitment by the Applicant to invest in 
improving Puerto Rico’s telephone and broadband services. Because of the real 
possibility that this commitment will better serve Puerto Rico, and because of the 
reporting obligations and the Commission’s monitoring and oversight capabilities to 
ensure that the promise becomes reality, I approve those parts of the Order. And I thank 
the Chairman for his work in developing support for the item.
I do, however, find the Order’s handling of foreign ownership issues troubling, 
and I must respectfully dissent to this analysis. The Applicant seeks control of U.S. 
Federal Communications Commission FCC 07-43
common carrier radio licenses comprised of 100% indirect foreign ownership of the 
acquired company and with 57% of the equity interest remaining unknown. To my 
knowledge, this will be the first time that an incumbent local exchange carrier is wholly-
owned by a foreign corporation and this is the largest percentage of unknown foreign 
ownership the Commission has ever approved. While most commenters appear more 
interested in ensuring substantial investments and real improvements in service for the 
people of Puerto Rico rather than preventing the transaction altogether, and while the 
Commission has previously relied upon WTO membership in approving transactions 
involving foreign ownership exceeding the ceilings set forth by statute, I remain 
concerned about our lack of inquiry and analysis to fully understand the implications of 
our actions in approving a transaction of this sort. When we consider the sale of our 
nation’s critical infrastructure to foreign owners – whether it be ports or telephone 
networks or utilities – we must always be extra cautious in our analysis. These are 
serious questions deserving a more thorough vetting. I believe in this case the 
Applicant’s public commitment, the safeguards and remedies available to us, and the 
commitment of the Commission to monitor implementation may be minimally adequate 
to produce a satisfactory result, but I also remain concerned about foreign ownership and 
the lack of transparency that can result from transactions like this.