Federal Communications Commission FCC 08-203
1
STATEMENT OF
COMMISSIONER ROBERT M. McDOWELL
Re: Petition of AT&T Inc. for Forbearance Under 47 U.S.C. § 160(c) From Enforcement of Certain 
of the Commission’s ARMIS Reporting Requirements; Petition of Qwest Corporation for 
Forbearance from Enforcement of the Commission’s ARMIS and 492A Reporting Requirements 
Pursuant to 47 U.S.C. § 160(c), WC Docket No. 07-139; Petition of the Embarq Local Operating 
Companies for Forbearance Under 47 U.S.C. § 160(c) From Enforcement of Certain of ARMIS 
Reporting Requirements, WC Docket No. 07-204; Petition of Frontier and Citizens ILECs For 
Forbearance Under 47 U.S.C. § 160(c) From Enforcement of Certain of the Commission’s ARMIS 
Reporting Requirements, WC Docket No. 07-204; Petition of Verizon For Forbearance Under 47 
U.S.C. § 160(c) From Enforcement of Certain of the Commission’s Recordkeeping and Reporting 
Requirements, WC Docket No. 07-273;Petition of AT&T Inc. For Forbearance Under 47 U.S.C. § 
160 From Enforcement of Certain of the Commission’s Cost Assignment Rules, WC Docket No. 07-
21;Service Quality, Customer Satisfaction, Infrastructure and Operating Data Gathering, WC 
Docket No. 08-190
I support AT&T's request for relief from the requirement to file ARMIS service quality and 
infrastructure reports in this forbearance petition and the extension of such relief to similarly situated 
carriers that have also requested such relief.  As set forth in the order, these reports, which are filed by 
only a small group of carriers, no longer advance the consumer protection goals for which they were 
originally adopted. With this order, we are able to maintain effective consumer safeguards while also 
cleaning out unnecessary regulatory underbrush.  Accordingly, I find that granting relief meets the 
statutory obligations of Section 10 and, therefore, is in the public interest.
I also am pleased that this item extends to Verizon and Qwest the relief the Commission 
previously afforded to AT&T eliminating certain cost allocation data collection and reporting 
requirements.  As I said at that time, it is important to grant comparable relief to similarly situated 
carriers, and to do so as soon as possible.
Even after this limited forbearance order, the Commission can still gather information necessary 
to build a sufficient record for a legitimate regulatory purpose. For example, we appropriately deny 
forbearance with respect to business line count information used in the non-impairment thresholds for the 
Commission’s unbundling rules. Further, some of the data currently provided in the ARMIS reports – if 
collected from a broader set of providers – could inform our decision-making with respect to public 
safety, broadband deployment, and perhaps other key issues.  I therefore look forward to reviewing the 
responses to the Notice of Proposed Rulemaking asking whether and how the Commission should collect 
data from a broader cross-section of the industry. The fact that the relief in this order is conditioned on 
carriers continuing to publicly file ARMIS report data for two years will, to the extent we conclude that 
the collection of such data by the Commission is necessary and proper, ensure continuity.