CONCURRING STATEMENT OF 
COMMISSIONER JESSICA ROSENWORCEL

Re: 	Petition of NTCA—The Rural Broadband Association and the United States Telecom Association for Forbearance Pursuant to 47 U.S.C. § 160(c) from Application of Contribution Obligations on Broadband Internet Access Transmission Services, WC Docket No. 17-206.
Our high-cost universal service fund program is designed to bring modern communications to rural America.  That’s a noble goal.  But the system we have to do so is not just complex, it’s Byzantine.  With the advance of time and technology, regulatory reforms have multiplied.  As a result, there are real quirks and strange inequities in our rules.  
Today we remedy one of them.  We grant non-model rural incumbent local exchange carriers forbearance from the universal service contributions related to one component of broadband internet access service.  
You got that?  Like I said, it’s complicated.
I concur in this decision.  As a matter of equity, I think it is important to put these carriers on equal footing with their peers.  But the analysis in this decision is lacking.  Moreover, while I think this is the right call today, I also believe it’s time for some basic math.  By granting this forbearance, we forego roughly $40 million in funding for broadband in rural America.  Add to this the $55 million in lost interest income that the FCC just gave up by shifting universal service bank accounts without even a vote and you have nearly $100 million in universal service funds that have disappeared.  
So I don’t just worry that our high-cost universal service system is complicated.  I worry that despite our noble rhetoric about closing the digital divide in rural America, we are draining this agency of the funds necessary to do so.