On May 22, 2018, National Lifeline Association (NaLA) representatives Kim Lehrman, Jose Cortes, Chuck Campbell, John Heitmann and Joshua Guyan met with legal advisors to Chairman Pai and Commissioners Carr, O’Rielly, and Rosenworcel to discuss proposed changes to the Lifeline program. NaLA does not agree with the ban on wireless resellers. They believe the FCC should support affordability and consumer choice, and also expressed support for a budget for the Lifeline Program.
NaLA representatives expressed that resellers are important in the Lifeline program. Getting rid of wireless resellers would:
Harm consumers by forcing more than 7 million or roughly 70% of all Lifeline subscribers to find a new Lifeline service provider, leaving some with no wireless or wireline service options.
Fail to bolster program integrity or guard against waste, fraud and abuse (adopting conduct-based standards and agent registration would properly focus on bad actors rather than on business models).
NOT bridge the digital divide by spurring additional facilities deployment or more affordable services.
Upend the states’ role in designating ETCs, as well as the reliance interests of wireless resellers who have willingly sought such designations and landline providers who have been relieved of the obligation to provide Lifeline (based on the presence of, and consumers’ preference for, the mobile voice and broadband services offered by wireless resellers).
NaLA representatives also explained that the FCC should support affordability. “The FCC should freeze or roll-back the minimum service standards and voice support phase-out that threaten to deny consumers access to affordable choices that best meet their needs.” NaLA was endorsed by National Association of Regulatory Utility Commissioners (NARUC) with a $2,258 budget and they expressed the support saying, “The Lifeline program could benefit from a self-enforcing budget mechanism that operates on an annual basis with prospective impact only.”
In this presentation, Chuck Campbell provided an overview of 2018 USAC activity, including the delay of the National Verifier, overdrive of the audit process, and universal Lifeline enrollment forms. Additionally, there was a review of common audit findings.
About Chuck Campbell:
Chuck has more than 25 years of experience delivering a wide variety of back office and integrated communications solutions to cutting edge and world-class clients in the finance, telecom and e-business sectors. His expertise in the past development of CGM’s suite of revenue assurance project tools has been integral in the development and deployment of both CABSoft and W.I.N. He has been instrumental in the deployment of systems as parts of enterprise-wide margin improvement projects for a variety of ICP clients. Additionally, he has directed the development of CGM’s M&A/Bankruptcy suite of services to meet the needs of the demanding CLEC and carrier marketplaces.
On May 18, 2018, National Association of Regulatory Utility Commissioners (NARUC) met separately with Commissioner Carr’s chief of staff and Chairman Pai’s legal advisor. NARUC expressed their support for the Lifeline Notice of Proposed Rulemaking (NPRM) proposal of respecting the state’s role in program administration regarding eliminating ETCs and suggesting cooperative federalism between the Commission and the states.
However, NARUC does not agree with the Lifeline NPRM proposal for eliminating non-facilities-based resellers. Lifeline NPRM said, “To advance our policy of focusing Lifeline support to encourage investment in voice- and broadband-capable networks, we propose limiting Lifeline support to broadband service provided over facilities-based broadband networks that also support voice service.” NARUC commented on Lifeline NPRM’s reasoning behind supporting facilities-based carriers because they feel it “might spur additional investment in infrastructure.”
NARUC’s stance is that non-facilities-based carriers should continue because, not only do they currently serve 75 percent of eligible users, they could also disrupt service to millions of eligible users.