STATEMENT
COMMISSIONER ROBERT M. McDOWELL
Re:  Electronic Tariff Filing System (ETFS), Report and Order, WC Docket No. 10-141 
As a general matter, I support efforts to streamline Commission procedures to 
make them more efficient for both the government and the public.  This order achieves 
that goal.  It makes good sense that nondominant carriers be required to follow the same 
electronic tariff filing system that incumbent local exchange carriers have used for years.  
So, after today’s order goes into effect, gone are the days of relying on an 
antiquated process of filing tariffs on physical paper and diskettes.  At least the “filing 
process” of the tariff system will be modernized.  On that note, I hope that in the future 
the Commission will look beyond reforming the filing procedures and also consider 
whether the day will ever come when we can discard the tariff system overall.  In fact, I 
propose that the Commission initiate a proceeding to examine whether, how and when we 
could accomplish such a goal.  If history is to be our guide, we are likely to find that 
markets and innovation have moved beyond the regulatory structures of the past. 
I thank the Wireline Competition Bureau staff their diligence on this order.     
Also, I commend the Chairman for his leadership in finding ways to modernize the 
Commission’s data collection procedures overall and look forward to working with all of 
my colleagues on streamlining other cumbersome and outdated FCC procedures.