Sign On: MAG-Net Lifeline Letter to the FCC

The Federal Communications Commission (FCC) is currently reviewing petitions to reconsider its March 2016 order to modernize the Lifeline program. The reforms will soon help millions of low-income families get online by making the cost of their Internet service more affordable. The Media Action Grassroots Network (MAG-Net), led by our members The Utility Reform Network and Greenlining Institute, waged a year-long campaign to win these reforms.

Petitions for Reconsideration have been filed by state regulators in addition to phone and Internet service providers who participate in the Lifeline program. MAG-Net will be filing comments to the FCC responding to some of these petitions. Comments are due to the FCC on July 29, 2016. Below is a broad overview of the recommendations we support and others we oppose. Please sign to have your organization included in our filing with the FCC. If you’d like to review the full set of comments before signing on please email Steven Renderos (steven@mediajustice.org)

We Support:

Some parties (which includes state regulators) make arguments that we are in agreement with. These arguments focus on two areas:

1. Requests that the FCC conduct a study of the affordability of telephone and broadband rates in 2018, rather than waiting until 2020.

2. Requests that the FCC continue to provide Lifeline subsidies for “voice-only” service (the FCC’s decision anticipates phasing out voice-only service).

We Oppose:

Some parties (all of whom are service providers) make arguments which would be detrimental to our communities. These arguments focus on three general areas:

1. Enrollment and Disenrollment rules

The FCC’s ruling creates a system where a “national verifier” will be responsible for confirming that Lifeline applicants are eligible for the program, and will be responsible for taking participants off the program if they no longer qualify or if the customer does not use the service for 30 days. Providers’ arguments are, essentially, arguments for making the enrollment process convenient for carriers at the expense of program participants.  The FCC’s waiting to make changes to the enrollment and de-enrollment process until after the National Verifier is in place would do nothing nothing to help our communities and could, in fact, make it harder for our communities to participate in the Lifeline program.  We cannot allow this to happen.

2. Weakened or Eliminated Service Quality Standards

Providers also argue that the Commission should eliminate service quality standards or let carriers “opt out” of service quality standards, or escape their obligation to provide Lifeline altogether. These requests would all result in Lifeline subscribers receiving substandard, “second-class” service.  Lifeline subscribers are entitled to the same level and quality of service as every other subscriber.  Providers should not be able to collect a generous Lifeline subsidy in exchange for offering low quality service, and we must fight providers’ attempts to weaken or eliminate service quality standards.

3. Restrictions on State Participation in the ETC process

To receive Lifeline subsides, providers must apply for, and be granted, Eligible Telecommunications Carrier (ETC) status.  The Lifeline statute expressly contemplates that states have a role in determining whether to grant ETC status.  Some providers are asking the Commission to eliminate or restrict state participation in ETC determinations.  States with a commitment to universal service (like Lifeline) perform an essential role in determining that Lifeline providers meet the needs of their customers.  We must work to preserve state participation in the ETC process. 

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