Petitioners Defend Requests for FCC Reconsideration of Lifeline Decisions
Parties that want the FCC to revisit its Lifeline USF overhaul answered critics of their petitions for reconsideration or clarification, which were the subject of recent oppositions and other initial comments (see 1608010028). Every petitioner filed a reply -- CTIA, General Communication Inc. (GCI), Joint Lifeline ETC Petitioners, the National Association of State Utility Consumer Advocates (NASUCA), NTCA/WTA, the Pennsylvania Public Utility Commission, TracFone and USTelecom. CenturyLink and New America's Open Technology Institute (OTI) also replied. Replies were posted in docket 11-42 Monday and Tuesday, with CTIA's filing the first to post (see 1608080042).
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The FCC should back off its planned phase-out of stand-alone voice Lifeline support, NASUCA said. It shared consumer group concerns about proposals to delay implementation of Lifeline broadband coverage and backed USTelecom's request the FCC reconsider its "freeze on the ability of Lifeline consumers to port service" (lasting 12 months for broadband consumers and 60 days for voice consumers). TracFone said Lifeline broadband coverage shouldn't come "at the high and avoidable cost of abolishing voice Lifeline service for those who rely on it for their communications needs."
There's a consensus the FCC didn't give adequate notice to require rolling certification by eligible telecom carriers, and much agreement the rule would harm Lifeline subscribers and ETCs, GCI said. Joint Lifeline ETC Petitioners said that The Greenlining Institute and other consumer groups "dramatically underestimate the burdens that rolling certification would have for consumers, ETCs" and program administration, and misunderstood their "bundle proposal and fail to appreciate the value bundled offerings" provide consumers. They said NASUCA "opposition to a streamlined voice ETC application process ignores the overwhelming evidence" that the current process takes too long.
Consumer groups and Joint Lifeline ETC Petitioners were wrong in claiming the NTCA/WTA petition "argues for 'second class' broadband service for rural low-income consumers," said the rural telco groups. The petition simply seeks to ensure support can be used for lower levels of broadband and even stand-alone voice service where higher-level broadband offerings don't exist, NTCA/WTA said. The Pennsylvania PUC answered NCTA and USTelecom opposition to its requests for clarifying the state role on new FCC-designated "Lifeline Broadband Providers," which includes "ordinary enforcement or consumer protection activities" the PUC doesn't believe were pre-empted.
Several USTelecom requests for relief were unopposed, including "rate adjustments that would conform" FCC rules to the updated Lifeline program, plus clarification of the ability of ETCs that previously sought forbearance to seek Lifeline Broadband Provider designation, the telco trade group said. CenturyLink said it backed USTelecom's petition plus the calls for delaying rolling recertification until the national verifier of consumer Lifeline eligibility is in place. The telco also supported allowing Lifeline discounts for any fixed broadband service offering, and reconsidering the 12-month port freeze on Lifeline broadband service.
CTIA, TracFone and the Joint Lifeline ETC Petitioners were incorrect in arguing the FCC didn't meaningfully analyze Lifeline affordability, OTI said. The FCC examined the concern, but took into account the "countervailing need to ensure that service plans are reasonably comparable" while taking steps to ensure Lifeline-backed plans are affordable, it said.