The following comments reflect are mainly directed at ensuring the USF has an effective, transparent and independent governance system including for the selection and implementation of the projects. Governing Body for Myanmar Universal Service Fund (Board of Trustees):  Establishing an independent governing body is crucial to be able to operate the Fund independently from any political or other influence. The draft strategy does not mention the governance of the Universal Service Fund. However a presentation made at the consultation session mentioned that there will be a five-member body called the Universal Service Fund Board of Trustees, and that this will include two representatives from the government (MoTC and PTD) and one representative each from NTL Nominee, Consumer Association or Accountant, and independent ICT/USF Expert. MCRB welcomes the presence of an ICT/USF expert, and believes that this person should be identified on the basis of clear ToRs/criteria, and in particular should have experience of governance of USF in other countries, and therefore could be a non-Myanmar citizen.  MCRB further believes that it is important that at least one representative is from civil society, in particular representing consumer interests and the rights of users. Therefore this candidate should not be an alternative to an accountant. Rather, if the Fund requires financial or accounting advice, this should be in the form of expert advisers and not a member of the Board.  While there are currently few organisations working on specifically on consumer issues for ICT and telecommunications products and services, our experience from discussions at the Digital Rights Forum and other contacts is that increasingly Myanmar consumer organisations are looking at these issues.  Furthermore MCRB believes there is an additional case to have a second member of civil society on the board with specific interest and expertise in transparency and accountability. Certainly if the Board were increased to more than five, particularly with the addition of further government representatives, MCRB believes that at least two of the representatives should come from civil society.  MCRB would be happy to assist the government in identifying a pool of candidates to draw from when identifying civil society participants. Alternatively the position(s) could be advertised based on clear criteria, including a requirement for the individual to have wellestablished networks with civil society and consumer groups.  MCRB would also be interested to know whether the USF will be subject to audit, and whether this will be by an independent professional third party, or the Auditor-General. Establishing flexible framework and targets  The draft Strategy sets targets mainly on two main goals of the USF; Availability and Accessibility: basic mobile voice services available to 99% of the population, mobile broadband services to 95% of the population, and voice and data services for 28 national highways and roads. However, the other two goals Affordability and Ability are also important and should also be addressed with special measures and targets.