**DISSENTING STATEMENT OF**

**COMMISSIONER MICHAEL J. COPPS**

*Re: High-Cost Universal Service Support,* *Federal-State Joint Board on
Universal Service, Alltel Communications, Inc., et al. Petitions for
Designation as Eligible Telecommunications Carriers, RCC Minnesota, Inc.
and RCC Atlantic, Inc. New Hampshire ETC Designation Amendment,* WC
Docket No. 05-337, CC Docket No. 96-45.

I dissent from today's decision to cap high-cost support for competitive
eligible telecommunications carriers (CETC) because it falls woefully
short of the fundamental, comprehensive reforms needed to meet the
overarching telecommunications challenge of the Twenty-first century.
That challenge, both by statute and by necessity, is to encourage the
deployment of basic and advanced telecommunications to all of our
citizens and to ensure that the Universal Service system, which
accomplished so much in the 20th Century, can do so again now. Today's
decision does nothing meaningful to meet that challenge; indeed, it only
deflects us from the goal. The outcome is an illusory band-aid that is
supposed to contain costs but, in reality, imposes the much heavier cost
of lost opportunity to reform Universal Service and put America back in
the vanguard of advanced telecommunications. As a result of today's
vote, real reform is on the back-burner. What a pity!

The need for reform is patently obvious. As this country continues to
lag in so many international broadband rankings and as consumers and
competitors around the world are receiving high-speed and high-value
services, Americans in urban and rural areas and on tribal lands are
falling further behind. One critical element of turning this ship around
is re-tooling the Universal Service system with broadband deployment as
its mission. And while my colleagues on the Federal-State Universal
Service Joint Board unanimously agreed to make broadband part of the
system, today's Order has the effect of putting this off to another day.
So too does it put off the many other difficult questions regarding
sustainability of the Fund that the Joint Board wrestled with and put in
its recommendations six months ago.

Comprehensive reform is not painless and may require shared sacrifice
from all stakeholders. Yet, today's piecemeal approach has the
unfortunate consequence of pushing interested parties apart rather than
bringing them all to the table to develop workable solutions. Just
consider that 365 days ago the Joint Board recommended an interim,
emergency high-cost cap. Since then Commission and stakeholder attention
has been largely focused on the merits and demerits of such a cap.
Today's Order ends up picking winners and losers when it comes to future
Universal Service support and increases the risk that no one will return
to the table to discuss real reform any time soon. Had all interested
parties spent the same time and energy over the last year focused on
comprehensive reform, we might "be there" already.

The Commission seems to forget that we do not have the luxury of time
here. Why is it slamming on the brakes when it comes to reform? The
Joint Board gave us more, and it is those proposals we should be
considering in a more comprehensive fashion. While I disagreed with some
of the Joint Board's recommendations, at a minimum they put us on the
road to real reform. The majority's response today, while they will
attempt to bill it as an "interim, emergency cap", has no sunset period
and commits only to completing comprehensive reform "as soon as
feasible." Remember that old song "The Twelfth of Never"?

While I strongly disagree with the overall decision taken today, I am
encouraged the majority added to their CETC cap two caveats that I have
long deemed important. The Order excludes from the cap high cost support
for CETCs serving tribal lands or Native Alaskan Regions. These areas
are among the most underserved when it comes to
telecommunications---both basic phone service and broadband. The
Commission must continue to focus on ways to bring affordable services
to these areas as their residents are equally deserving of the benefits
that technology affords. Second, a CETC will not be subject to the cap
to the extent it provides cost data documenting its actual costs for
providing competitive service. I continue to believe that the
elimination of the Identical Support rule should be part of any
comprehensive solution and this step is consistent with that approach.

I, for one, will continue to beat the drums for comprehensive Universal
Service reform. It's what Congress wants, what the statute commands, and
what consumers deserve. So I pledge today to do everything I can to
encourage all stakeholders to come to the table and take on the
unfinished business of empowering all our citizens through the awesome
new tools of communications technology.