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Separate Statement of Commissioner Harold W. Furchtgott-Roth

In re: Notice of Proposed Rule Making

1998 Biennial Regulatory Review -- Amendment of Parts 2, 25 and 68 of the Commission's Rules to Further Streamline the Equipment Authorization Process for Radio Frequency and Telephone Terminal Equipment and to Implement Mutual Recognition Agreements

I support adoption of this NPRM. In my view, any reduction of unnecessary regulatory burdens is beneficial. To that extent, this item is good and I am all for it. This item should not, however, be mistaken for compliance with Section 11 of the Communications Act.

As I have explained previously, I question whether the FCC is prepared to meet its statutory obligation to review all of the regulations covered by Section 11 in 1998. See generally 1998 Biennial Regulatory Review -- Review of Computer III and ONA Safeguards and Requirements, 13 FCC Rcd 6040 (Jan. 29, 1998). To my knowledge, the FCC has no plans to review affirmatively all regulations applicable to the operations or activities of telecommunications providers and to make specific findings as to their continued necessity. Nor has the Commission issued general principles to guide our "public interest" analysis and decision-making process across the wide range of FCC regulations.

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