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A. 1. a.(1)(a) i) a) I. 1. 1. a.(1)(a) i) a)#Xj\  P6G;ynXP#  &i   #Xw PE37|XP#&i`(#(#1  `(#June 22, 1998  Ѓ  X4 SEDISSENTING STATEMENT OFl  COMMISSIONER HAROLD FURCHTGOTTROTH l  Wv4 Re:XFifth Order on Reconsideration and Fourth Report and Order Regarding the Federal W_4State Joint Board on Universal Service, (CC Docket No 9645 ). (#  YH4  X 4X Introduction and Summary  If love could conquer all, if good intentions always led to good consequences, if hard work were always rewarded with good results, then this Order would be an impeccable work of art. It is the embodiment of immeasurable hard work, good intentions, and, dare I say, love. It embodies hope: hope for a better world in which more funding for new technologies is hoped to lead to better school facilities which are hoped to lead to better education which in turn is hoped to lead to a brighter future for the next generation of America. Good intentions and hard work are not enough for this Order. It is the third in a series of Orders to impose new taxes to support schools and libraries and other partial  Y4implementations of Section 254. I have dissented from these earlier Orders, Y4ԍ#Xw PE37|XP#Dissenting Statement of Commissioner Harold FurchtgottRoth Regarding Federal  Yh4State Joint Board on Universal Service, CC Docket 9645, Third Order on Reconsideration,  YS412 FCC Rcd 22801 (1997); Statement of Commissioner Harold FurchtgottRoth Regarding the Second Quarter 1998 Universal Service Contribution Factors, rel. March 20, 1998. and I unfortunately must dissent from this Order. In my view, the current Order does not accurately or even approximately reflect either the letter or the spirit of the law. I dissent with the utmost respect for the efforts and hopes of my colleagues. But, I dissent also because of my utmost respect for the language of the Telecommunications Act of 1996 and Section 254 in particular.  Ye4 The Telecommunications Act of 1996 embodies the hopes of many Americans: more innovation, more services, more consumer choices, lower consumer prices, less regulation, and universal service. I believe the Act can and will meet these hopes of the American people. But I believe that these hopes will only be met if the Commission is faithful to the language of the Act. I fear the current Order is not.  Y4 Neither are the Commission's actions today faithful to the original intent of Congress or the current demands of Congressional leaders because as I stated only a month ago in"!60*((PP"  Y4this Commission's last report to Congress: priorities matter.EP Yy4ԍ#Xw PE37|XP#Dissenting Statement of Commissioner Harold FurchtgottRoth Regarding the Report to Congress in Response to Senate Bill 1768 and Conference Report on H.R. 3579, rel. May  YK48, 1998.#x6X@`7X@#E I remain convinced that rural, highcost universal service is not just one of many objectives of Section 254; it should be the  Y4highest priority. The federal government has had universal service programs for rural, high Y4cost areas and for lowincome Americans for many years. Section 254 embodied these ideals and set forth goals that emphasize rural, highcost support as well as lowincome support and other objectives. But, despite repeated Congressional demands that the FCC "suspend further collection of funding for its schools and libraries program, and proceed with a rulemaking that  Y34implements all universal service programs in a manner that reflects the priorities established  Y 4by Congress in the Telecommunications Act of 1996,"Ax KP Y4ԍ#Xw PE37|XP#See, e.g., Letter from The Honorable John McCain, Chairman, Senate Committee on Commerce; The Honorable Ernest F. Hollings, Ranking Minority Member, Senate Committee on Commerce; The Honorable Tom Bliley, Chairman, House Committee on Commerce; The Honorable John D. Dingell, Ranking Minority Member, House Committee on Commerce; to The Honorable William Kennard, Chairman, Federal Communications  Y4Commission, June 4, 1998. #x6X@`7X@#A the Commission continues to proceed with selected universal service programs while at the same time delaying these higher priority issues. Rural, highcost universal service issues should not be resolved and implemented in some dim and distant future after all other universal service issues have been  Y 4resolved; rural, highcost universal service issues should be resolved and implemented first. Rural, highcost universal service should not be viewed as the residual after enormous amounts for other federal universal service obligations have been promised; rural, highcost  Y}4universal service should receive the lion's share of any increase in the federal universal service fund. To understand fully my other concerns about this Order, one need only read one of  Y#4my several statements related to universal service.L_# P Y_4ԍ#Xw PE37|XP#See Dissenting Statement of Commissioner Harold FurchtgottRoth Regarding Federal  YJ 4State Joint Board on Universal Service, CC Docket 9645, Third Order on Reconsideration,  Y5!412 FCC Rcd 22801 (1997); Statement of Commissioner Harold FurchtgottRoth Regarding the Second Quarter 1998 Universal Service Contribution Factors, rel. March 20, 1998; Dissenting Statement of Commissioner Harold FurchtgottRoth Regarding the FederalState Joint Board Report to Congress, rel. April 10, 1998; Dissenting Statement of Commissioner Harold FurchtgottRoth Regarding the Report to Congress in Response to Senate Bill 1768 and Conference Report on H.R. 3579, rel. May 8,1998; Statement of Commissioner Harold"%0*&&w%" FurchtgottRoth Regarding the Common Carrier Bureau's Proposed Revisions of 1998 Collection Amounts For Schools and Libraries and Rural Health Care Universal Service Support Mechanisms, rel. May 13, 1998; Statement of Commissioner Harold FurchtgottRoth Regarding the Common Carrier Bureau's Clarification of "Services" Eligible for Discounts to  Y44Schools and Libraries, rel. June 11,#Xw PE37|XP# 1998; Statement of Commissioner Harold FurchtgottRoth Regarding the Common Carrier Bureau's Third Quarter 1998 Universal Service  Y4Contribution Factors, rel. June 12, 1998. #x6X@`7X@# My view of universal service is not"#0*&&PP;" universally shared. Not everyone here at the Commission or in the public agrees that Congress' universal service priority was the rural and high cost program. Not everyone here at the Commission agrees that the Telecommunications Act clearly contemplates "a single proceeding" to implement all of the universal service provisions, including both the schools  Y4and libraries and the rural, highcost programs.P YD 4ԍ#Xw PE37|XP#47 U.S.C. Section 254(a)(2).#x6X@`7X@#ћ Others have different views. I would call many of these other views "myths." Perhaps others might call my views "myths" as well, or worse. I describe these views as myths not in a pejorative sense, but in the sense of evolved folklore that has not been scrutinized. For, as we shall see, even the slightest scrutiny reveals the fiction of these stories. Below I list 15 of what I consider to be the myths most relevant to this Order. Doubtlessly, there are many more.  X 4 1.Longdistance rates have gone down; therefore, we need not worry about new  X 4taxes on longdistance services. The real issue is not whether rates have gone up or down, but whether they would have been lower absent the new tax. Longdistance rates have gone down in recent years, but they would have gone down further without unnecessary fees and taxes for the Schools and Libraries Corporation. Under current rules, most support for the Schools and Libraries Corporation is borne by longdistance customers. Phone taxes in general, and longdistance taxes in particular,  Y4are some of the most inefficient and punishing taxes faced by the American consumer. Prof. Jerry Hausman of MIT has estimated that consumers lose more than $2 for every dollar in  Y4longdistance taxes. P Y"4ԍ#Xw PE37|XP#Jerry Hausman, "Taxation by Telecommunications Regulation," National Bureau for  Y"4Economic Research, Working Paper Series 6260, November 1997.#x6X@`7X@# Telephone services are already one of the more heavily taxed services based on usage through federal excise taxes, federal universal service taxes, state and local excise"|: 0*&&PPF" taxes far more heavily taxed than the typical 5 percent sales tax that consumers pay for typical goods and services. These heavy excise taxes discourage use, weaken demand, stifle investment, and retard innovation. Ironically, at a time when the federal government is contemplating stiff new taxes on tobacco products partly to reduce demand for what is perceived to be a harmful product, the  Yv4federal government has also imposed new taxes on telecommunications services. Are telecommunications services perceived to be as harmful as tobacco?  X14 2.Access charge reductions offset any increase in universal service fund  X 4contributions. I remain concerned with recent attempts to tie reductions in access charges to the  Y 4level of universal service contributions.& P YN4ԍ#XR PjQ|XP#Today's Order does not use access charge reductions to increase universal service obligations. But, the Common Carrier Bureau had proposed using all access charge reductions to fund universal service, and this concept has been referenced when justifying  Y 4previous funding increases. See, e.g., footnote 73 accompanying para. 24 of the Collection  Y4Public Notice.  #Xx6X@DQX@#& Even to the extent that federalmandated access charges have been reduced to offset increases in universal service obligations, almost 20% of the schools and libraries contributors do not benefit from reduced access charges. Thus, for example, wireless carriers have paid proportionately higher fees, despite the fact that they have received no access charge reduction. Moreover, there is no assurance that the consumers who benefit from access charge reductions will be the same consumers who will bear the new universal service burden. For example, business consumers could disproportionately benefit from the access charge reduction while residential consumers pay for new universal service fees. The issue should not be whether, despite massive tax increases that just offset decreases in federal access fee and charges, IXCs have no net differences in costs. The issue should be whether, absent massive new taxes, consumers would be better off.  X4  X43.Line items for new taxes related to universal service are simply a means to develop a "hidden rate increase."  YN4 This assertion defies economics and common sense. If long distance carriers could pad their profit margins by simply adding useless line items on their bills, companies would have already done it. But adding line items is not a means to higher profits. In a competitive market, prices are determined by costs. If a business tries to raise"!0*&&PPg" prices above its actual costs, it will lose its customers to competitors that have not raised prices. Many economists believe that longdistance service is a relatively competitive market. Simple economics and market realities dictate that competitive businesses must pass along new taxes to their customers. Competitive businesses take prices as given by costs not by the wishes of outside spectators. Those who claim that a business should not pass along a new tax to consumers are simply saying that the business is not competitive in the first place; only a noncompetitive business has the luxury of not passing all of a tax along to consumers. In addition, a new tax and higher costs will likely reduce net market demand thereby reducing the number of firms that a competitive market can support. Moreover, even if longdistance carriers were not competitive, they would still pass along part of a new tax to consumers. To the extent that taxes raise prices and thereby reduce market demand for a service, profits in an industry are likely to decrease as the result of a new tax. Consequently, a new tax cannot plausibly be a blessing to the longdistance industry, whether it is competitive or not. Line items for new taxes are a means of letting customers understand why rates are not lower than they would be absent the new taxes. These line items are not a means of promoting "hidden rate increases." To the contrary, the only "hidden rate increases" would occur if rates were higher as the result of hidden and unexplained taxes. Only a stupid and foolish firm destined for failure in the American telecommunications market could fantasize about profiting from a new tax. I have yet to meet a viable firm in any market that appeared to be stupid or foolish. I have also never met a stupid or foolish consumer. And I have yet to meet an American consumer who doesn't want to be told about a new tax.  Xe4 4.The federal government should tell businesses to inform customers only about net new taxes, not about new taxes that are offset by decreases in existing taxes.  Y74 It would be easy to dismiss this myth as a flagrant violation of the First Amendment. But even if government should interfere with truthful communication between a business and its customer an interference that should never happen customers should always know about new taxes, even if other taxes have decreased substantially more. The issue for consumers is not just whether prices have gone up or down, but also whether prices would be lower absent a new tax. Only in Washington could disclosure of such a new tax be considered deceptive. Depriving businesses of the opportunity to converse freely with their customers is a flagrant violation of the First Amendment. Depriving consumers of information about new"Q%0*&&PPe#" taxes demoralizes a democratic society. If the British government had successfully hidden new taxes from American colonists in the middle 18th Century, we might today still be saluting the Union Jack. Doubtlessly, the British government of that time may well have tried to hide the series of new taxes and regulation of commerce from the American colonists. Efforts by governments to hide information from the public may work in the short term, but never in the long term.  XH4 5.The new tax rates in this Order reflect a reduction in tax rates that would otherwise result.  Y 4 Technically, absent Commission action, a higher tax rate would result on July 1, 1998 because of the automatic increase for funding the schools and libraries program that would otherwise take place. However, that increase in the tax rate has only been delayed for one year. The Commission does nothing to adjust the annual $2.25 billion cap, which will instead go into effect next July. Thus, on July 1, 1999 there will be another increase in the quarterly contribution to the schools and libraries fund of almost $240 million, or another 75% increase. It should also be noted that while the Schools and Libraries Corporation has  Y44estimated $2.02 billion in demand for the first year of the program4P Y4ԍ#Xw PE37|XP#Third Quarter 1998 Fund Size Requirements for the Schools and Libraries Universal  Y4Service Program, dated May 1, 1998.#x6X@`7X@# the Commission's Order today authorizes $1.925 billion to be disbursed over the next 12 months (July 1, 1998 to July 1, 1999). While this amount does not fully meet demand and it precludes funding additional applications, I am not sure how much of the initial demand will go unmet by this "cut." Moreover, even the proposed tax rate for the remainder of 1998 is higher than the most responsible tax rate zero. The Schools and Libraries Corporation has already raised enough revenue to fund practically all requests for telecommunications services in 1998, the only item eligible for discounts under the Act. The real issue is not whether the rate is higher or lower than it would be if an arbitrary deadline is not met; the real issue is whether tax rates are as low as they could be and as low as they should. The answer is a resounding "no!" Rates can and should be zero for the remainder of 1998.  X4 6.There is great urgency to adopt this rule and proceed with wiring the schools immediately.  Y 4 Enormous efforts have been made, probably entirely well intentioned, to rush this"!b0*&&PP" item through the Commission by midJune. The rationale given is that carriers need time to adjust their July bills. Last December, rates were changed and carriers somehow managed to change their January bills. Moreover, the rates changed last December did not legally go  Y4into effect until February,| 3P Y44ԍ#Xw PE37|XP#The Commission's Third Universal Service Reconsideration Order, adopted in December, 1997, explicitly waived the APA's 30day requirement because it was deemed critical to implement the new schools and library program on January 1, 1998. Thus, the rules that were necessary to calculate the lower universal service contribution factors were to be effective upon publication in the Federal Register. These rules were not published in the Federal Register until January 27, 1998. Moreover, as published, that Order clearly states that "[t]he rules adopted in this Order will become effective February 26, 1998." Thus, technically, the contribution rates were not legally in effect at least until January 27, if not  Y~ 4until February 26. #x6X@`7X@#| yet billing disasters did not ensue. Further delays may yet occur. Most Senators at last week's hearing encouraged the Commission at least to freeze temporarily this program while the Commission revisits both the substance and the rampup period of these new universal service programs. Indeed, in response to Sen. Wyden's (DOre.) suggestion that FCC take 68 weeks to fix the universal service program, I stated that I would welcome the opportunity. I had hoped that the Commission would follow Sen. Wyden's counsel to suspend the program and make a public commitment to address the entire universal service dilemma including the rural, highcost issues in the next 68 weeks. X` hp x (#%'0*,.8135@8:4State Joint Board on Universal Service, at para. 27.pp"#Xx6X@DQX@#' As several commenters noted, however, "[b]oth the Congressional Budget Office and the Office of Management and  Y4Budget count payments into the fund as federal revenues and payments out of the fund as  Y4federal outlays.",b  Y#4ԍ#Xw PE37|XP#Comments of Sprint PCS, at 7. #x6X@`7X@#ў Third, I continue to object to the fact that the contributions for the schools, libraries,"i ,0*&&PPJ"  Y4and rural health care support mechanisms are based not only on interstate but also on  Y4intrastate revenues. As I have described on several occasions, the legality of this approach to  Y4calculating contributions is highly questionable.- YO4ԍ#Xw PE37|XP#Separate Statement of Commissioner Harold FurchtgottRoth Regarding the Second Quarter 1998 Universal Service Contribution Factors, rel. March 20, 1998; Dissenting Statement of Commissioner Harold FurchtgottRoth Regarding the FederalState Joint Board  Y 4Report to Congress, rel. April 10, 1998. #x6X@`7X@#ѻ As I read the Communications Act, it does not permit the Commission to assess contributions for universal service support mechanisms based on intrastate revenues. Rather, the Act makes clear that the power to collect charges  Y4based on such revenues rests within the exclusive province of the States..4 Yv 4ԍ#Xw PE37|XP#Indeed, it has been reported that at least one state Virginia has ordered that MCI stop applying federal surcharges on intrastate long distance calls made in that state and make  YH 4appropriate refunds to customers. Communications Daily, May 11, 1998. #x6X@`7X@#ђ Fourth, I fail to see how the Commission may lawfully differentiate among otherwise "bona fide requests." The Commission's rules already consider a schools' economic status in determining the level of support to which they may qualify. Now the Commission will take economic status into account to determine whether the schools are even eligible for participation at least participation in funding for inside wiring, despite the fact that the schools have submitted an otherwise "bona fide request" under our rules. If the Commission's rules already addressed such discrepancies in economic advantage adequately, then the newest proposal seems, at best, unfair to schools that will now be prohibited from participating, if not altogether arbitrary. Indeed, I do not see how the Commission has the discretion to prioritize among such bona fide applications. The universal service provisions mandate that "upon a bona fide request" the "telecommunications carriers . . . shall" provide  Yf4a discount./f Y4ԍ#Xw PE37|XP#47 U.S.C.A. section 254(h)(1)(B)#x6X@`7X@#. All of the applications that met our previous rules are bona fide requests, and the Commission has not determined that its previous rules were incorrect as I have urged. As such, I am concerned that the Commission has failed to establish a system that would fund all such bona fide requests as required. The statute does not endorse differentiating among such bona fide requests; the current plan to fund internal wiring based on need cannot be what Congress intended.  Y4 13.The Schools and Libraries Corporation is efficient . The Common Carrier Bureau Public Notice regarding the third quarter contribution factors also established the administrative expenses for the Schools and Libraries Corporation. In objecting to the second quarter contribution factors, I noted that Schools and Libraries Corporation was allocated almost four times as much money for administrative"Sh /0*&&PP " expenses as the highcost/low income funds and that the administrative budget increased from $2.7 million to $4.4 million or by 65% in just one quarter. These increased administrative expenses continue in the third quarter, despite the fact that the Schools and Libraries Corporation has still failed to provide an accurate estimate of all its administrative costs for  Y4the first quarter.0 Y4ԍ#Xw PE37|XP#Third Quarter 1998 Fund Size Requirements for the Schools and Libraries Universal  Y4Service Program, dated May 1, 1998.#x6X@`7X@# In contrast the administrative expenses for both the High Cost and Low Income programs combined is only $1.2 million. I cannot endorse such a disparity and certainly not one of this magnitude between the administrative expenses of the Schools and Libraries and those of the other universal service corporations, especially without more adequate safeguards against excessive spending by the schools and libraries program.  X 4 14.The FCC's interpretation of universal service reflects the intention of Congress.  Y 4 As noted above, the FCC's interpretation of universal service does not follow the letter of the law. Based on the recent correspondence from Congress, it is clear that the  Y 4FCC's interpretation of universal service does not follow the spirit of the law either.1J b Y4ԍ#Xw PE37|XP#See, e.g., Letter from The Honorable John McCain, Chairman, Senate Committee on Commerce; The Honorable Ernest F. Hollings, Ranking Minority Member, Senate Committee on Commerce; The Honorable Tom Bliley, Chairman, House Committee on Commerce; The Honorable John D. Dingell, Ranking Minority Member, House Committee on Commerce; to The Honorable William Kennard, Chairman, Federal Communications Commission, June 4, 1998; Letter from The Honorable John D. Dingell, Ranking Minority Member, House Committee on Commerce, to The Honorable William Kennard, Chairman,  Y44Federal Communications Commission, June 4, 1998.#x6X@`7X@# In particular, the Commission has failed to complete work on the highest Congressional priority, rural highcost service, while creating massive new unintended grant programs for schools and libraries.  XM4 15. There is no good solution to the problem. There is a good solution to the problem. It is to follow the intent of Congress. That advice is eloquently phrased in the recent letter from the leadership of the Commerce Committees of both the House and the Senate. If we follow the advice of Congress, we will set the collection rate for the schools and libraries program to zero until such time as we can resolve the highest universal service priority: rural, highcost support.  X~4 Conclusion "gt 10*&&PP#"ԌMost observers of politics and telecommunications regulation in Washington would agree that the Commission's handling of universal service over the past two years has led to a great deal of handwringing. Some would say that we have made substantial progress, but no one would say that we solved all of the problems related to universal service. Some would say that we are not headed in the right direction; many go so far as to say that we should stop and start over again. The problem with the FCC's implementation of Section 254 is not one of intent or effort. Many hardworking, wellintentioned people have dedicated the better part of two years of their lives to working on the implementation of this section. Their efforts have not been in vain. We have learned much about both what is possible and not possible under Section 254; we have learned something about what is not sustainable; we have learned about concerns of consumers who thought that the Telecommunications Act would lead to changes in regulations that would allow rates go down, not merely stay the same or increase; we have learned about the fears and concerns of rural America when its understanding of Section 254 is not adequately addressed. Above all, we have learned that Section 254 is one of the most difficult and most important sections of the Act. Despite good intentions and efforts, some mistakes have been made in the implementation of Section 254 over the past two years. The best outcome would be to learn from those mistakes; the worst outcome would be to ignore them. Congressional leaders have demanded that the Commission suspend the schools and libraries program until all aspects of universal service are resolved. I believe the Congressional leaders are correct. It would be perhaps irresponsible to issue funding commitments, allow public money to be distributed, or to raise consumers rates which is undeniably necessary at least with respect to wireless rates if not overall to pay for these programs before Congressional concerns can be fully addressed. America is a great nation not because we have the most advanced technologies in the world. We are a great nation because we are a nation whose People love liberty, whose government serves the People, and whose government is governed by laws written by the People. When government agencies follow the law as it is written, there is no greater investment in our future.  The proponents of the Erate program often cite its educational value. The Erate, we are told, is an "investment" in the future of America. I believe the FCC can and ought to make a contribution to the education of American children. Our greatest contribution, however, is not in serving as a tax collector, even for the most wonderful of programs. Our greatest contribution is in following the law, and being a showcase for democracy. Some in America believe that all of the parts of Section 254 cannot be implemented,"Q%10*&&PPe#" that the section is hopelessly complicated and selfcontradictory. According to these skeptics, it is time to give up. It is time to rewrite the section, or worse, implement only part of it. The inevitability of defeat is palpable among the skeptics. I believe the skeptics are wrong. I believe that Section 254 can be fully implemented. I believe that a strict and narrow reading of the law is not only what Congress intended but also the only way by which Section 254 can be fully implemented. We at the FCC can and must rededicate ourselves to following the letter of the Communications Act, and Section 254 in particular, as written by Congress. We must, as Congressional leaders have suggested, start over. It will be a difficult process, but it is possible, and it is urgent. In the meantime, the American public can rest assured that no new taxes will be levied by the FCC, that universal service will remain accessible to all Americans under existing rules, and that schools and libraries will continue to receive ten billion of dollars of federal support annually for infrastructure in addition to countless billions of dollars from state and local governments and countless billions more from the private sector. In the end, the FCC will have contributed far more to the education of American children than any amount of funds for any educational purpose. The FCC, building on its past good intentions and good efforts, will have taught a lesson that the greatest myths are the myth of inevitable defeat and the myth that government agencies cannot solve difficult problems.