Federal Communications Commission FCC 07J-1 
STATEMENTOF
COMMISSIONER LARRY S.  LANDIS
In the Matter of High-Cost Universal Service Support, WC Docket No.  05-337; Federal-State Joint 
Board on Universal Service, CC Docket No.  96-45
In recent weeks, the bulk of the attention by various parties offering ex parte comments in this 
proceeding has been devoted to certain anticipated aspects of the proposed interim emergency cap which 
is addressed in todays Recommended Decision.  I can appreciate the concern of various parties with 
regard to how (without knowing the exact parameters of the proposed cap) it might impact them.  Much 
has been said and written about the need for competitively and technologically neutral policies, 
disregarding the fact that in some respects the current regime is anything but.
The basic facts are inescapable, as set forth in the Recommended Decision.  Growth in high cost 
support on the current trend line is unsustainable.  A number of proposals were offered in ex parte filings 
as alternatives, with the intent of sharing the pain among various groups of providers.  Those proposals 
fail to address the fact that for most segments, growth has been virtually flat or even modestly negative in 
the short run; there is only one group of providers which have seen dramatic and continued growth, and 
that group is wireless CETCs.
To use an analogy, if you are offering emergency medical treatment to a badly injured person who is 
bleeding profusely from the arm, you dont address the short-term problem by applying a tourniquet to 
the patients leg.  Having said that, a tourniquet is not a long-term or permanent solution, and neither is 
the interim emergency cap.
While the growth is attributable to CETCs, most of which are wireless carriers, they are simply 
operating under the current laws and rules, once they have received ETC designation.  Over the course of 
the past several months, I have come to a greater appreciation of the extent to which there are wireless 
companies which operate on a business model targeted primarily to serving rural areas, and which 
contribute significantly to realizing the goal of providing truly universal service to areas where costs are 
such that no business case can be made for buildout, absent Universal Service support.
At the same time, there are many rural areas where multiple wireless providers are active.  Where there 
is already competition, we need to make sure we dont inadvertently advantage one company over the 
others which entered that market based on a competitive, unsubsidized model.  Indeed, it may be time to 
ask if the presence of some minimum number of competitors greater than one in a market is a prima facie 
indicator that the market is contestable and competitive, and that no universal service support should be 
rendered to the competing providers in that market.
The states have an obligation and a growing partner role with the FCC as joint stewards in seeing to it 
that Universal Service funds are appropriately deployed, that legitimate needs are met, but that 
accountability and performance are audited and demanded.
Now that the interim Recommended Decision has been approved by this body, it is my hope that we 
can move on to the far more significant and far-reaching issues and potential solutions addressed in the 
companion Request for Comment.
The Request for Comment raises the question of whether the Joint Board and the Commission should 
consider adding broadband to the list of supported services.  It is my hope that the parties will examine 
not only the threshold questions (is penetration sufficient for broadband to qualify as a supported 
service?) but also, if they conclude that broadband should be a supported service, how that can best and 
most efficiently be implemented.  What are the appropriate threshold funding obligations of providers? Of 
the several states, including (but not limited to) state funds and other incentives? And of the high cost 
funds? These potential interrelationships require closer examination.
Federal Communications Commission FCC 07J-1 
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Finally, I appreciate the concerns of those who have suggested that the interim emergency cap will 
somehow morph into an intermediate or long-term default patch to the issues we propose to examine.  
By explicitly committing to making further recommendations regarding long term, comprehensive high-
cost universal service reform within six months, and by proposing that the cap expire one year from the 
date when such recommendations are offered, I hope that we have convinced interested parties that the 
Joint Board is determined to address those long term issues in a meaningful, thoughtful and aggressive 
manner.
If we are to do so, we will need to build a record which is considerably more comprehensive and 
provides greater granularity than that which we have today.  Interested parties simply need to move with 
dispatch.  The clock is running for all parties with an interest in the outcome of this deliberation.  As such, 
the record will be only as robust as the parties make it.