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Reseller Role Backed

Opposition Builds to FCC Proposal to Shift Lifeline Support to Facilities-Based Providers

Parties opposed an FCC plan to retarget Lifeline USF to facilities-based providers and impose certain other funding restrictions, in comments being posted this week in docket 17-287 on an NPRM and notice of inquiry (see 1711160021). "This package of proposals runs the risk of harming over eight million Lifeline households and millions more eligible veterans, older Americans, and households with school-aged children,” said Olivia Wein, National Consumer Law Center attorney, in a release Wednesday highlighting NCLC comments filed with many other groups. The FCC plan "to restrict and reduce Lifeline services will cut off whole communities from these necessary connections," commented the United States Conference of Catholic Bishops, urging rejection of "proposals to radically disrupt the Lifeline program."

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Consumer groups, civil rights groups, industry parties and others said resellers should be able to continue providing the subsidized broadband and voice services to low-income consumers. Free State Foundation President Randolph May agreed reseller support shouldn't be discontinued. Some state regulators and other consumer groups earlier filed opposition to the facilities-based proposal before an original deadline was extended (see 1801260038), and NARUC last week adopted a resolution urging continued reseller Lifeline participation (see 1802140022).

Removing reseller eligibility would jeopardize service to over 70 percent of Lifeline subscribers, said commenters. "Elimination of non-facilities-based providers will leave large portions of the country without a choice in Lifeline provider and could result in no Lifeline coverage for some parts of the country," commented the Low-Income Consumer Advocates, a collection of 22 groups, including the Benton Foundation, Common Cause, Consumer Union, NAACP, NCLC, Public Citizens, Public Knowledge and United Church of Christ Office of Communication. “Millions of poor families would lose their Lifeline service provider, with no assurance that there would be another Lifeline service provider to serve them,” said Cheryl Leanza, UCC policy adviser.

The Leadership Conference on Civil and Human Rights and 200 organizations (here) said Lifeline voice support should continue in all areas, not just rural ones, and they opposed FCC proposals to set a hard budget cap and require consumer co-pays. Their comments were similar to the Low-Income Consumer Advocates, which also opposed an NOI idea to impose benefit limits on households or individuals. Common Sense Kids Action also opposed "a proposal to limit WiFi devices and hotspots."

Others objecting to the proposed facilities-based requirement included AARP, Communications Workers of America, Incompas, Mobile Beacon, the National Association of State Utility Consumer Advocates, National Digital Inclusion Alliance (NDIA), National Lifeline Association (NLA), Korean War Veterans Association, National Housing Conference, TracFone Wireless, Oseti Sakowin Tribal Utility Authority (OSTUA) and Medicaid providers (here, here). Because Lifeline support is passed through to subscribers, "it does not directly support the build out of facilities" even if provided through facilities-based providers, NLA said. OSTUA said "wireless resellers are the primary providers of Lifeline service, Tribal members prefer wireless service to wireline service to meet their needs, Tribal members rely on the Lifeline discount to obtain wireless service, and the Tribal Lifeline discount (up to an additional $25.00 per month) is necessary to make voice and broadband service affordable on Tribal lands."

NLA also said most other FCC proposals to restrict funding would "eliminate the ability and/or dampen the incentives for reputable companies that want to participate in Lifeline to serve those who really need it." AARP urged the FCC to "reject the unreasonable proposals" in the NPRM that "will reduce the ability of low-income households to access the critical telecommunications services that are essential to everyday lives of all Americans." Some opposed an FCC proposal to scrap Lifeline broadband provider designations, including Mobile Beacon, NDIA and DANEnet.

FSF's May said Lifeline is a valuable "safety net" for low-income consumers "truly in need," though it should be run efficiently. "While promoting increased facilities investment is, in general, a worthwhile objective, the primary purpose of the Lifeline program is to promote the affordability of communications services for low-income persons," he commented. He understood the impulse that motivates FCC proposals to eliminate resellers and impose a hard cap, but opposed their adoption "without a further convincing demonstration of need." May did "support the pro-consumer, pro-empowerment proposal to allow providers to meet the minimum service standard through plans that provide subscribers with a particular number of 'units' that can be used either for voice minutes or broadband service."