STATEMENT OF 
COMMISSIONER MICHAEL O’RIELLY
Re: Connect America Fund, WC Docket No. 10-90, Allband Communications Cooperative
Petition for Waiver of Certain High-Cost Universal Service Rules.
When a universal service funding recipient seeks a waiver of Commission rules to obtain 
additional support, the company must be prepared to demonstrate that there is good cause to grant the 
request.  That includes providing complete and accurate documentation to support its request.  Then, the 
Commission has the responsibility, on behalf of all businesses and consumers that pay into the universal 
service fund, to conduct a thorough review to ensure that the amount of support we provide is necessary 
and appropriate.  
If it comes to the Commission’s attention that the amount of support provided may not be fully 
justified, the Commission must examine the facts and make appropriate adjustments consistent with our 
rules.  At the same time, absent any indication of intentional wrongdoing, the Commission should not be 
unnecessarily hasty in recouping support provided pursuant to a previously granted waiver if it is unsure 
whether some amount of additional support would have been appropriate.  This is particularly important 
in instances where consumers could lose access to voice service in areas where there are no other 
providers, as could be the case in this instance.  It would be odd indeed for the same Commission that just 
voted extra “protections” for consumers switching voice service during tech transitions to turn a blind eye 
to the plight of consumers that could lose service altogether.  
Therefore, I am pleased that my colleagues agreed to defer any claw back of support until a 
determination can be made about what amount of support should have been provided.  To be clear, I have 
no difficulty recouping the full amount of funding provided under the waiver—to the extent that the facts 
and circumstances justify that step.  The company will also have the opportunity to seek a new waiver
once it revises its documentation consistent with our rules.  I urge the company, USAC, and the 
Commission to work expeditiously to resolve these outstanding questions.