CONCURRING STATEMENT OF
COMMISSIONER MIGNON L. CLYBURN
Re:   Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure 
Investment, WC Docket No. 17-84.
Let me say up front: despite the fact that this item tees up some ideas I am uncomfortable with, I 
will respectfully concur. I want to thank the Chairman for working with me to address some of my 
substantial concerns, in particular, revisiting the test for streamlined voice discontinuance, and adding in 
less aggressive language regarding our interactions with localities.
Indeed, there is much on which we can agree. The time is ripe for opening up pole attachment 
reform, for taking a look at how we can work with local governments to remove barriers to deployment, 
and for generally evaluating how we can further streamline processes for rolling out new services. What 
concerns me, however, is the strong talk surrounding preemption, that takes place even before we lay out 
a clear path to work with communities through other processes such as the Broadband Deployment 
Advisory Committee’s development of model codes. The importance of community engagement was 
reiterated during my visit earlier this week to the Digital Southwest summit in Mesa, Arizona, and it is 
with this backdrop that I look forward to reviewing the full record on all of these issues.
However, when it comes to the Commission’s efforts to start a proceeding to roll back the 
carefully considered efforts of the past Administration to carve a path forward for technology transitions, 
I remain extremely concerned. This Commission seems to view paying customers who subscribe to 
legacy services as a barrier to infrastructure deployment, and that is problematic for me. 
A RAND study from last year found that approximately 20 percent of Americans view landline 
telephone service as the most important communications service, beating out mobile voice, mobile 
broadband, and fixed broadband. And this group may, according to RAND, “include the more vulnerable 
members of society.” Indeed, a majority of fixed voice customers, still choose legacy telephone service 
despite other options that may be available in the marketplace. And while they certainly may be out there, 
I have yet to come across a consumer who is clamoring for their landline service, to be converted to 
interconnected voice-over-IP service.
This item, at least as it was originally drafted, primarily ensured that large carriers, not 
consumers, got what they want. These carriers’ balance sheets are heavily inked with operating 
expenditures associated with legacy services. It is no secret, that it would indeed be more efficient for 
carriers to migrate all of their customers off of legacy services as quickly as possible. But as regulators, 
we are charged with protecting the public interest, and the public interest standard goes beyond operating 
efficiencies. 
Rather than properly wrestling with these difficult issues however, the Commission implies that 
efficient technology transitions override consumer desires and consumer protections. At the end of the 
day, these transitions are either about replacing electronics on either end of a wire, or replacing that wire 
with fiber or other technologies. But those infrastructure changes promise to fundamentally alter the very 
nature of the service offered to consumers. This is exactly why we must ensure that consumers’ concerns 
and needs are given credence during this process of retiring copper or discontinuing legacy services. On 
the road from legacy to modern services, this item seeks comment on removing stop signs and traffic 
lights along the way. I only hope, that we do not crash and burn.
I thank the staff of the Wireline Competition Bureau for their hard work and professionalism. 
These are incredibly difficult issues, and I understand you pulled this item together very quickly, and you 
did so very well.