STATEMENT OF
COMMISSIONER MIGNON L. CLYBURN
APPROVING IN PART AND CONCURRING IN PART
Re: Comprehensive Review of the Part 32 Uniform System of Accounts, WC Docket No. 14-130; 
Jurisdictional Separations and Referral to the Federal-State Joint Board, CC Docket No. 80-286.
Until today, Section 220 of the Communications Act required all regulated telephone companies 
to keep their accounting books in a uniform manner. This in and of itself is not an unusual condition, for 
there are many other industries, both regulated and unregulated that use this system of uniformity, to 
include hotels, restaurants, marinas and boatyards. Even the “destination marketing” industry (yes, that is 
a real term), has a uniform system of accounts that diverges in certain respects from generally accepted 
accounting principles, or GAAP. So it is worth mentioning, that price cap telephone companies asked to 
be exempted from an accounting system that many other industries readily employ to ensure uniformity.
But we have met at this juncture before. When first faced with whether to forbear from requiring 
this data in 2013, I agreed that forbearance was unwarranted, and it is also worth mentioning that the 
Commission’s view was upheld by the court. The mere existence of data can act as an insurance policy 
against bad behavior. Today, we are cancelling that policy.
I am concerned that we are acting too soon. While the majority cites our reforms of intercarrier 
compensation, as justification for no longer needing uniform bookkeeping, we are still years away from 
bill-and-keep for terminating access charges. And might I note, that the Commission has yet to reform 
originating access charges. 
I also fear that our action will be cited to our state counterparts as the main reason why they will 
no longer need a uniform system of accounts in their state regulatory structure. Just as we have seen state 
legislatures deregulate in the face of promises, that federal rules will protect consumers, federal 
deregulation has also been used to leverage state deregulation. This is especially problematic here, where
the lack of a federal need, does not equate to a lack of state need for such regulation. In fact, quite the 
opposite is true.  
Let me be clear, I believe that it is high time we reform Part 32 of our rules: the section dealing 
with uniform accounting. Streamlining the number of accounts, allowing carriers to reprice assets at 
market value after a transaction, and incorporating the concept of materiality into accounting practices for 
example, are good ideas that I am glad we are implementing.
And since accounting for costs related to pole attachments are still critically relevant, regardless 
of accounting method, I am pleased that we act to make sure, that data regarding pole costs remain 
transparent and easily accessible for several years. I only wish we could have gone further to protect 
attachers from rate shock, as this may happen as pole owners switch to GAAP accounting.
Yes, today’s action will provide bookkeeping flexibility to price cap carriers. However, the result 
of these changes will be less uniformity and certainty going forward, which in turn, may mean comparing 
apples to oranges when we look at carrier costs. And because I am not wholly convinced that we are 
completely free of our need for this data in the future, I respectfully concur in part. 
So to those carriers who advocate for decreased regulatory burdens, let me assure you: I am with 
you. However, the next time this Commission or a state commission asks for cost data, to support a 
rulemaking, investigate a complaint, or bring an enforcement action, I hope we do not hear protestations
that the request is too burdensome because the data is not kept in the format that the FCC or state 
commission needs. 
To the staff of the Wireline Competition Bureau, I again thank you for all your hard work on this 
item, as well as your efforts over the years in implementing the Uniform System of Accounts.