Support for National Lifeline Database Reaffirmed in Lifeline Replies

Broad support exists for the commission to establish a national Lifeline eligibility database, AT&T said (http://xrl.us/bm5z7x). “With seven different federal qualifying programs for non-Tribal Lifeline service, it is simply infeasible (and bad public policy) for almost a thousand Lifeline providers to obtain direct access to, possibly, seven different databases per state to confirm consumer eligibility for the Lifeline program,” the carrier wrote, arguing “almost every commenter” agrees that the database must be national in scope. AT&T also urged the commission to “act swiftly” to prohibit resellers from obtaining Lifeline-discounted service from ILECs. “Like AT&T, other commenters recognized that the sweeping reforms that the Commission made in its Order could be undermined if the Commission continues to permit resellers to obtain Lifeline-discounted service from ILECs,” it said. AT&T reiterated its request to permit providers to opt out of the Lifeline program.

Sprint Nextel, whose affiliate Virgin Mobile USA is a Lifeline service, opposes mandated application of the Lifeline discount to all eligible telecom carrier offerings that include a voice component (http://xrl.us/bm5z9n). Sprint said the order explicitly let ETCs bundle service packages with a voice component, and apply the Lifeline discount to a bundled service package. “The Commission wisely stopped short of mandating that ETCs make available a Lifeline discount on all service offerings,” Sprint said, arguing there could be substantial costs of mandating a discount on prepaid wireless ETCs. The information technology changes alone could cost millions of dollars for Virgin Mobile, and there would be several related costs to ensure compliance, the carrier said. “Sprint respectfully submits that before the Commission contemplates imposing a mandate that the current rules explicitly permitting the application of the Lifeline discount to bundled service be permitted to take hold in the Lifeline marketplace."

Smith Bagley urged that the national database only be used for eligibility checks (http://xrl.us/bm52ha). “It is critical that the Commission ensure that Lifeline participants’ personal information is protected with only the minimum necessary information made availability to ETCs,” it said, arguing it would be “wholly inappropriate” if the database became a tool that facilitated direct marketing. The carrier, which serves tens of thousands of Native American Lifeline subscribers, said the commission should provide support for more than one Lifeline per household, especially in tribal areas.

Supporting creation of a national database, Nexus Communications urged the commission to increase the monthly reimbursement level from $9.25 to at least $9.58 (http://xrl.us/bm52aq). “Nexus agrees with NASUCA that a modest increase of $0.75 is needed to offset some of the effects of both High Cost and Lifeline reforms,” it said. “Nexus believes that the Commission should increase the interim rate to somewhere between $9.58 and $10.00, and at a later date, undertake a separate proceeding focused on reimbursement rate after the industry has had time to absorb the numerous and significant changes to the Lifeline program.” Nexus also argued against a 10-year record retention period, which it called “unnecessary and overly burdensome.”

Budget PrePay, a wireless ETC in seven states, encourages a flat rate of at least $9.25 in Lifeline support for five years, and “opposes the use of economic modeling to try to develop the ‘perfect’ rate” (http://xrl.us/bm52hk). InComm, a prepaid provider, encouraged the commission to clarify that the Universal Service Administrative Co. must select a neutral vendor for the Lifeline duplicates database “through an open, fair and transparent competitive bidding process” (http://xrl.us/bm52hz). The Regulatory Commission of Alaska wants the FCC to “pause and allow time for carriers to assess the effects of the approved reforms before adopting further changes” (http://xrl.us/bm52h7). Only ETCs providing service directly to customers should receive Lifeline support, ILECs should be relieved of the obligation to resell, and the current flat rate reimbursement of $9.25 per month should be maintained in Alaska, it said.