Federal Communications Commission FCC 13-16 
STATEMENT OF 
COMMISSIONER MIGNON L. CLYBURN
Re: Connect America Fund, WC Docket No. 10-90, High-Cost Universal Service Support, WC 
Docket No. 05-337.
The USF/ICC Transformation Order was an historic overhaul of the high-cost Universal 
Service Fund (the “Fund”). The main purpose for this bold reorientation of the Fund was to bring 
robust broadband networks to consumers living in high-cost geographic areas, where the private 
sector business case has yet to support such service.  In addition, the unanimously approved
bipartisan effort determined that certain reforms were needed to ensure that carriers were 
incentivized not only to invest in broadband networks, but to do so efficiently and effectively.  
The FCC’s determination to modify the high-cost loop support mechanism for rate-of-return 
carriers was an important step, and I fully supported the benchmarking rule that was adopted and 
implemented by the Wireline Competition Bureau.  
As we explained in the USF/ICC Transformation Order and again in today’s Sixth 
Reconsideration Order, the lack of the right incentives under the Commission’s old rule was 
problematic and unsustainable.  The essential modifications we make today to the benchmarks 
not only will provide more flexibility, but will continue to operate as a moderating tool—a 
checks and balances, if you will—which will encourage efficient investment and operational 
expenses by rate-of-return carriers as intended by the USF/ICC Transformation Order.  Our 
focus has been providing the appropriate financial incentives for carriers to invest in broadband 
networks, balanced with the overall impact on our objective to reach as many consumers as 
possible with our limited high-cost budget.  In doing so, the issue of predictability has been 
raised, and while our initial analysis indicates that carriers could predict their funding under the 
current benchmarks, we are directing the Bureau’s implementation of limited adjustments to 
ensure that predictability continues.  I support the Commission’s efforts to modify reforms as 
needed, while staying true to our overall objectives in the USF/ICC Transformation Order—to 
ensure that the Fund is being used to deploy broadband in the most efficient and effective 
manner, reaching as many consumers as possible, in order to provide truly universal voice and 
broadband service.