SEPARATE STATEMENT OF 
COMMISSIONER MICHAEL J. COPPS

Re:  	Performance Measurements and Standards for Unbundled Network Elements and 
Interconnection 

I support launching this proceeding to consider national performance standards 
and penalties.  Uniform national standards have the potential to promote regulatory 
efficiency, allow benchmarking and comparisons among carriers operating in different 
States, and reduce the administrative burdens of myriad different requirements.  I noted 
the benefits of uniform standards just last month in a dissenting statement to the 
Accounting Further Notice in which the Commission concluded that it should eliminate a 
uniform national accounting system and instead move to a patchwork of State 
regulations.  

For the effort we launch today to succeed, however, we must work closely with 
our State colleagues.  Many States have already established performance metrics and 
penalties.  We should draw on their experience and work cooperatively to implement  
measurements that will provide the information we need and the State commissions need 
to carry out our statutory obligations.

Finally, I would have preferred to also seek comment in this notice on 
performance standards on the provisioning of special access services.  The need for 
performance measurements may be even more urgent for these services.  Whereas 
numerous States have adopted standards for network elements and interconnection, 
several States have indicated that they lack jurisdiction over interstate services.  One 
State Commission, New York, has expressed concern about the provisioning of these 
services, and its Chair has asked the FCC to deal with this issue or delegate authority to 
the States so they can address any problems.  

I believe it would have made sense to consider all of these performance 
measurement issues together.  The same facilities are used to provide special access 
services and unbundled network elements.  Competitors often secure loops, transport, and 
combinations of network elements through special access tariffs in lieu of using network 
elements.  Indeed, a significant portion of local competition is provided over special 
access circuits.  Given that these services are not only an integral part of interexchange 
services, but are also used by competitors to provide local services, it would have been 
logical in terms of resources, efficiency, and common sense to consider these issues 
together.  

Nevertheless, I vote for this notice with the understanding that the Commission 
will issue another notice in the near future to consider performance standards for the 
provisioning of special access services.  I urge the Commission to move forward with this 
notice in the near future and to consider the issues in tandem.