STATEMENT OF
COMMISSIONER MICHAEL O’RIELLY
Re: Connect America Fund, WC Docket No, 10-90; Universal Service Reform – Mobility Fund, 
WT Docket No. 10-208
When the Commission established rules for the Mobility Fund Phase II earlier this year, I worked 
with my colleagues to include a challenge process to confirm which areas should be eligible for funding.  
Decisions premised on inaccurate data or faulty assumptions could result in either wasteful overbuilding 
or a loss of service for consumers. Therefore, we sought comment on a challenge process to ensure that 
these vital decisions would be based on the best possible data without overburdening participants or staff
or creating undue delays.
The order before us today appears to have struck an appropriate balance on all counts.  While this 
process will involve a new data collection, which is not something to be undertaken lightly, the order 
attempts to standardize and streamline the requirements, which is intended to make the process more 
efficient and expeditious overall.  In addition, the order seems to set reasonable parameters to maximize 
coverage while targeting areas that are truly unserved.  In each of the high-cost programs, the 
Commission has worked hard to find the sweet spot that will ensure that our scarce ratepayer funds are 
used where they are needed most.  Consistent with our prior decisions, we have decided to direct this 
funding to the higher-cost unserved areas that are less likely to be served through market forces.  Finally, 
in order for a challenge process to be successful, participants must have time to assemble the necessary 
filings.  Therefore, I am pleased that the order has been revised to provide a longer timeline to gather and 
submit data.  
I will vote to approve.