This joint statement responds to today's filing with the Federal Communications Commission by advocates of the "Missoula Plan" seeking changes to the intercarrier compensation and universal service systems. The parties listed below have participated in or followed the efforts of the NARUC Intercarrier Compensation Task Force, and appreciate the valuable work of the state commissions that volunteered resources to this difficult task. NARUC has not taken a position on the substance of the Missoula Plan.

While the undersigned organizations and entities may not agree on every aspect of intercarrier compensation reform, they oppose the Missoula Plan. The undersigned parties agree that the Missoula Plan does not serve the interests of consumers because it does not adequately address and in many cases would exacerbate problems with the current intercarrier compensation and universal service systems – e.g., uneconomic regulatory distinctions and incentives for inefficiency.

The wide diversity of stakeholders listed below demonstrates that, as filed, the Missoula Plan is not the appropriate vehicle for reforming the intercarrier compensation system and should not serve as the framework for future discussions. We look forward to the opportunity to participate in the FCC process to develop a plan that results in pro-competitive, pro-consumer intercarrier compensation reform.