Letter to Tom Wheeler, Chairman Federal Communications Commission - Offer Support, Guidance to FCC on its Plan to Expand Broadband Access through Lifeline Program

Letter

Dear Chairman Wheeler:

We are writing in support of the FCC's proposal to modernize the Universal Service Fund's Lifeline program. In order to fulfill its purpose of meeting the changing needs of low-income Americans, the FCC should update the program to reflect the increasing importance of the Internet. Broadband has evolved to become an essential vehicle for expanding access to information, health services, educational resources, and employment opportunities. Often deprived of these opportunities due to the cost of broadband, low-income households are further disadvantaged in society.

To best serve these Americans, the Lifeline subsidy should be made portable to all telecommunications services whether offered as standalone services, or as bundle packages. This would allow the consumers to elect which service best meets their individual needs, applying the subsidy as a credit. Additionally, if a consumer is dissatisfied with a particular provider's service, they should be able to easily opt out and subscribe to another provider without transfer and disconnection fees. Not only would this best serve consumers and ensure they are receiving the best quality service at an affordable cost, but it would also encourage competition among providers to provide the best plan.

The FCC should also provide guidance on the program that discourages providers from using the Lifeline program as a means to commit consumers to long term billing relationships. The program should avoid requiring credit checks, banking account requirements, and disclosure of subscription history. Additionally, an ideal Lifeline broadband plan would be one that does not require the subscriber to contribute anything more than the subsidy. Under the basic, entry-level broadband subscription contract, consumers would not be required to make any investment in the providers' services, but they would also not be discouraged from upgrading their plans in the future should their needs change. The Commission should also instruct participating providers not to levy conversion or installation fees that would essentially be punishing the subscribers for taking advantage of the Lifeline program.

The broadband services available to the eligible households should not sacrifice quality for affordability. The standard would allow for functional, not subpar, internet access to define the entry-level Lifeline plan. Its flexibility would reflect evolving provider capability, program requirements, and support for higher speeds. The standard should also be relative to the capacity of an area as to prevent consumers from being excluded from applying to Lifeline because their community does not have the infrastructure to support higher speeds. Establishing a minimum standard prevents providers from taking advantage of the subsidy by offering second-class service that would not best serve the digital needs of an average American.

Acknowledging that many people access the Internet through their wireless devices, the FCC should include wireless Internet coverage under the Lifeline program to increase broadband accessibility for households. To account for the different capabilities of the two services, respective minimum standards should be established for each service. The standard for wireless should avoid small data caps, as well, to avoid overages resulting in fees for the consumer.

Rather than allowing providers to oversee the eligibility verification of consumers as the Lifeline program expands to include broadband, the FCC should streamline the process with preexisting databases for other federal assistance programs. This coordination would allow for co-enrollment, as many consumers eligible for programs such as SNAP or TANF would also be eligible to subscribe for Lifeline, but it would not eliminate the income-level qualifier. The process would remove the burden from qualifying Americans by simplifying the application process for not only Lifeline, but other assistance programs as well, and it would help improve program integrity.

We applaud the Commission's efforts to bring the Lifeline program up to date to 21st century standards with its proposed inclusion of broadband service. With this new service, low-income Americans would have the means necessary to access essential health and social services, educational resources, employment information, and communication networks. We encourage the Commission to implement the expansion as soon as possible, as we cannot be inactive and allow the digital divide to further deepen at the expense of the 53% of low-income households without broadband access.