CONCURRING STATEMENT OF
COMMISSIONER MICHAEL J. COPPS
In the matter of High-Cost Universal Service Support, Federal-State Joint Board on Universal Service, 
Lifeline and Link Up Support, WC Docket Nos. 05-337 and 03-103, and CC Docket No. 96-45
In 2005, the Commission issued an NPRM tentatively concluding that high-
cost Universal Service funding in Puerto Rico should be increased to raise telephone penetration rates—
the lowest in the country.  I agreed with the tentative conclusion, voted to approve the NPRM and 
expected that the Commission would proceed to an Order setting up a funding mechanism that would 
attend to the specific needs of Puerto Rico.  That Commission failed to follow through, however, and no 
action was taken to address the concerns raised in the NPRM. At the end of 2008, PRTC filed a petition 
for a writ of mandamus before the D.C. Circuit seeking Commission action on the 2005 NPRM. While I 
was Acting Chairman, on behalf of the Commission I committed to a timeline for addressing the matter.
And the present Commission has dutifully stuck by that timeline, culminating in today’s Order.  Finally 
we take a much needed closer look at the critical issue of telephone service in Puerto Rico. 
However, I can only concur in today’s decision.  While I can understand the road the majority is 
traveling—and even my colleagues’ reasons for doing so—I cannot, as someone who has been pushing 
for resolution for so many years, wholeheartedly endorse the more gradualist approach we take today. 
The Order finds that circumstances have changed in Puerto Rico and the justifications for the 2005 
tentative conclusions are no longer valid. I agree that the situation has changed: according to some 
calculations, voice penetration in Puerto Rico is now 91.9%, a marked improvement from the less than 
three-quarters take rate that the Commission observed in 2005. In addition, the 
collective Universal Service support going to providers in Puerto Rico—support to CETCs as well 
as Lifeline support—has increased significantly. This suggests that the Commission’s Universal Service 
funds have changed the telecommunications access in Puerto Rico for the better. But better is not good 
enough for the good people of Puerto Rico.  Voice penetration there still falls significantly below the 
national average. Furthermore, the insular nature of Puerto Rico, as well as its low median household 
income—roughly one third of the national median household income—create a unique situation which 
should not be overlooked any longer.  More is needed here.  
The Order points out that the Commission cannot address the immediate voice 
telecommunications needs of the people of Puerto Rico because our focus is shifting 
from Universal Service support of legacy voice services to comprehensive Universal Service reform for 
high-speed broadband services. Since I arrived at the Commission, I have encouraged the adoption and 
implementation of a national plan that would make ubiquitous, affordable high speed, value-laden 
broadband service a reality. While some areas of the country are seeing such service now, or may see it 
in the near future through infrastructure upgrades, the record shows that there are areas in Puerto Rico that 
have no infrastructure. Not only is voice service not available, but there is no wireline foundation for 
broadband service either—putting the people of Puerto Rico that much further from getting the broadband 
service that we recognize as a necessity in the Digital Age. I do hope we can move forward with 
implementing the National Broadband Plan to make sure that these areas that lack service—insular, as 
well as tribal areas and rural areas—at least get the same service that the rest of the country already takes 
for granted. But, again, this is a longer-term approach to a serious near-term problem.  
I am somewhat heartened by the proposal in today’s Notice of Proposed Rulemaking to increase 
support through the Link Up Program in Puerto Rico. The additional support would be used to offset 
facility construction charges for getting voice service to eligible subscribers. The problem of low voice 
penetration in Puerto Rico—while improved in recent years—still remains. Based on the household 
income numbers in Puerto Rico, it appears that additional funding for build-out and service to subscribers 
with particular financial needs would be helpful.  Now we will have to wait to review the record on this 
Notice to understand how the proposal will work, and, should we find that the proposal is a good one, we 
will have to wait even longer for an Order adopting rules to implement it. It is a shame that the people of 
Puerto Rico must wait so long for infrastructure and service levels that the rest of the United States is 
already experiencing.  But I do expect that this Commission will move swiftly on this proposal and adopt 
programs that will encourage broadband deployment and adoption in Puerto Rico. Let’s not wait another 
five years to see that Puerto Rico gets the voice and broadband service that it needs.