Federal Communications Commission FCC 12-137
STATEMENT OF
COMMISSIONER JESSICA ROSENWORCEL
Re: Connect America Fund; A National Broadband Plan for Our Future; Establishing Just
and Reasonable Rates for Local Exchange Carriers, High-Cost Universal Service
Support; Developing an Unfled Intercarrier Compensation Regime; Federal-State Joint
Board on Universal Service; Lfeline and Link- Up; Mobility Fund, WC Docket Nos.
10-90, 07-35, 05-337, 03-109; GN Docket No. 09-5 1; CC Docket Nos. 01-92, 96-45; WT
Docket No. 10-208
Last year, the Commission took historic steps to update its high-cost universal service fund and
intercarrier compensation system. It did so to refocus these longstanding policies from the
communications challenge of the last century-voice telephony-to the broadband and wireless networks
so essential for 21St century economic and civic life. In doing so, it also put the high-cost fund on a
budget and required greater accountability from fund recipients. These are good developments.
Today, we make adjustments to our financial reporting obligations for privately-held rate of
return companies and provide further guidance and clarification on our standard for requests for waiver of
our universal service reforms, which I fully support. However, this agency's reforms to the high-cost
universal service system are extremely complex. I fear that this complexity can deny rural carriers
dependent on them the certainty they need to confidently invest in their network infrastructure. So when
opportunities arise to simplify our rules in a manner that is fiscally sound, good for investment, and good
for rural consumers-I think we should seize them.
To this end, I look forward to working with my colleagues at the Commission to act quickly on
two fronts. First, I believe we should combine the two separate capital and operating expense
benchmarks into one benchmark to simplify the regression analysis and provide carriers with flexibility to
meet our new limits. Second, I believe we need to take a hard look at keeping our benchmarks in place
for a longer period of time, instead of resetting them annually. I think this would help ensure that we
have in place a more predictable system that provides carriers with more confidence to invest in
broadband infrastructure.
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