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NaLA Submits Comments to Senate Universal Service Fund Working Group

Senate Universal Service Fund (USF) Working Group sought comments on program effectiveness and necessary reforms

As the only ecosystem-based organization focused on ensuring that low-income Americans have sustainable, affordable access to essential communications services, NaLA has submitted comments to the Senate Universal Service Fund (USF) Working Group focused on ensuring that low-income Americans have sustainably affordable access to essential communications each and every month.

NaLA’s members include service providers, distributors, network access aggregators, compliance and software solutions vendors, device manufacturers, enrollment representatives, program supporters and beneficiaries invested in the future of the Lifeline and ACP programs. NaLA notes that wireless resellers play an important part in ensuring the success of these programs, including by serving over a third of all ACP subscribers.

The USF Working Group is seeking comments on the effectiveness of – and necessary reforms to – the programs funded by the universal service fund, which includes Lifeline.

Some highlights from the comments NaLA submitted:

NaLA submits that with ACP funding set to run out as early as April 2024, appropriated funding will be needed at least until USF reform can be accomplished.
NaLA proposes that either Congress and the FCC consolidate the Lifeline program with the ACP or reform both so that they better serve the goal of making essential communications services sustainably affordable each and every month.
NaLA recommends that any future low-income program should incorporate key program design elements from the ACP, including a robust monthly service and device benefits, technology neutrality, reasonable benefit transfer limits, and a safe harbor and entry requirements that encourage competition that translates into compelling choices and value for eligible consumers.
NaLA maintains that program integrity can be preserved by conforming eligibility requirements and by reliance on the National Verifier which should be subject to continuous improvement and greater transparency.
NaLA submits that the effectiveness of a low-income support program should be measured by whether low-income households have sustainably affordable access to essential communications services. Adoption is a secondary benefit that can be addressed only in part by a low-income affordable connectivity benefit program.

The full comments, including an executive summary, are available here.

08/24/2023 Glen Echo Group Lifeline Advocacy, Lifeline News No comments

Next Century Cities Congressional Briefing Advocates for ACP Refunding

On July 19, NaLA along with The Pew Charitable Trusts, Buckeye Regional Council, Common Sense Media, and Next Century Cities hosted experts and community leaders for a Congressional Briefing focused on the Affordable Connectivity Program (ACP) at the Nelson Mullins office. The discussion highlighted the significant impact of the ACP and emphasized the need for its continuation and strengthening.

The event featured keynote remarks from Doug McCollough, CIO of Dublin, Ohio and Mike Lynch, Legislative & Regulatory Affairs Director at NATOA and a panel discussion moderated by Kathryn de Wit from The Pew Charitable Trusts with panelists: Kenya Asli from the City of Baltimore, Maryland; Ryan Collins from the Buckeye Hills Regional Council of Governments; Khotan Harmon from the City of Austin, Texas; and Drew Garner, State Broadband Policy Advisor from Common Sense Media.

During his keynote remarks, McCollough acknowledged that while the ACP may not be the permanent solution for broadband accessibility, it has been a catalyst for progress in digital equity. The program’s innovative nature has forced various stakeholders to work together, and to advocate for high-quality broadband access for everyone, especially underserved communities. He also recognized the pivotal role of service providers in ensuring the program’s success and acknowledged the importance of communities being empowered to voice their needs effectively.

Panelists shared insightful perspectives on some of those communities. For example, Garner emphasized that 98 percent of students use the internet for homework, highlighting the need for universal connectivity to ensure equal educational opportunities. Asli discussed how the ACP has allowed previously underserved communities to engage in the digital economy. She emphasized that as more government resources and services move online, we will need to ensure equitable and sustainable access to these resources for all citizens. Collins noted that access to the internet opens doors to telehealth and remote work, offering critical opportunities for economic growth in communities.

The panelists agreed that there is an urgent need for additional ACP funds. Garner stressed the importance of the device component in the ACP and emphasized the necessity of broadband subsidies to ensure universal affordable connectivity.

Collins emphasized the importance of fiscal responsibility in continuing ACP funding, as it serves as the foundation for community prosperity and access to the global culture. He explained that a loss of ACP funding would “pull the rug out from under all that opportunity,” that has been built in rural areas. Communities “need access to the global culture so these communities don’t feel isolated. People can survive without the internet, but they can’t truly thrive. Thus, without it, it will take them back. It will suck the air out of the community”.

The panelists’ unanimous call for continued funding underscores the impact of the ACP in ensuring that millions of Americans can thrive in the digital age. NaLA believes that closing the digital divide means making broadband affordable for all Americans so that they can stay connected each and every month. We advocate for the continuation of this program to ensure individuals and families are not left without affordable and consistent access to essential online services.

08/08/2023 Glen Echo Group Member News No comments

NaLA releases findings from 2022 Annual Consumer Survey

Results from more than 60,000 respondents indicate that consumers need affordable access to mobile wireless voice and broadband services to participate equally in all facets of daily life

NaLA’s Annual Survey of Lifeline and Affordable Connectivity Program subscribers – conducted between November 21 and December 8, 2022 provides insights into consumer demographics and experiences with FCC internet subsidy programs.

The survey results indicate that low-income consumers use Lifeline and/or ACP service to connect to family and to access other government programs, healthcare, jobs and online education.

2022 Key Takeaways

Consumers want and need mobile wireless: More than half of those surveyed said they would choose to have mobile and fixed broadband service if they could afford both, but 43% said mobile wireless services best meet their household needs. Only 2.5% of those surveyed say fixed broadband alone would suffice.
Voice, text and data are all essential. While nearly 80% of consumers surveyed value access to voice, text and data equally, consumers indicated making and receiving calls as the most important form of communication.
Consumers want choice and control of their benefits. More than 90% of those surveyed prefer having the ability to combine Lifeline and ACP support in order to get more robust benefits. This practice is currently prohibited in the state of California, but it’s clear consumers prefer to have the ability to combine benefits.
Low-income consumers need affordable access to more mobile broadband than they currently use on limited plans and budgets. More than 90% of consumers throttle their data usage over the course of the month because they cannot afford to purchase more on top of their capped plans.
No co-pay plans are essential to keeping low-income Americans connected. Nearly 95% of Lifeline and ACP subscribers say they cannot afford any additional payments toward wireless and broadband services. Lifeline and ACP are essential to keep low-income Americans connected.
Most Lifeline/ACP subscribers lack access to credit and are unbanked. More than half of Lifeline/ACP subscribers surveyed do not have a debit or credit card or a bank account.

“Imagine life without mobile wireless access to the internet in 2022. It’s nearly impossible to conceive of how a family could function. But without programs like Lifeline and ACP, many Americans would not have a phone number or an internet connection and would be cut off from society,” said David B. Dorwart, Chairman of the NaLA Board. “NaLA’s survey shows that the majority of Lifeline and ACP recipients live below the Federal Poverty Guidelines. This means that our programs are working to bring connectivity to those who need help the most. It is crucial that lawmakers continue to support these programs to ensure that all Americans have affordable access to essential communications.”

The full results, including more insights into demographics, are available here. Download the one-pager of these highlights here.

Read the official press release here.

12/14/2022 Glen Echo Group FCC, Lifeline Advocacy, Lifeline News, Press Releases No comments

Source: FCC | Wikimedia Commons | Jessica Rosenworcel

The National Lifeline Association (NaLA) congratulates FCC Chairwoman Jessica Rosenworcel on her confirmation by the U.S. Senate to become the first woman to serve as permanent chair of the FCC. On this historic day, David Dorwart, Chairman of NaLA proclaimed that “NaLA looks forward to working with Chairwoman Rosenworcel, her fellow commissioners, and the talented FCC staff on making sure that Lifeline and the Affordable Connectivity Program meet the challenges of providing affordable broadband options for all Americans.”

As NaLA explains in its comments publicly filed today, the first priority for the new FCC Chairwoman should be the successful transition from the Emergency Broadband Benefit Program (EBBP) to the Affordable Connectivity Program (ACP) on December 31, 2021. With Congress having removed the barrier to competition and consumer choice contained in the original legislation, eligible consumers will be able to apply the benefit to any plan, including those specifically designed to maximize the use of available benefits and broadband connectivity. The FCC should refrain from imposing conditions or approvals processes on plan offerings. Congress already has decided all plans must be available with ACP discounts. Further, existing subscribers receiving EBBP benefits must transition automatically into the ACP with notice and the right to switch plans, opt-out, or transfer their benefit to another provider. Imposing an opt-in requirement would likely result in more than half of EBB subscribers losing their supported broadband service after the 60-day transition period.

In its comments, NaLA also notes that Lifeline subscribers in the three National Lifeline Accountability Database (NLAD) opt-out states have faced an unfair and prejudicial delay in being able to opt-in to the EBB, which the Bureau proposes to continue into the ACP. Even though the statute permits any provider to use an alternative verification process (AVP) that guards against waste, fraud, and abuse, the Bureau has refused to approve any AVP that would allow Lifeline ETCs to rely on the NLAD opt-out state administrators’ Lifeline eligibility approvals. Additionally, the Universal Service Administrative Company (USAC) has declined to accept real-time API access to the California state administrator database of eligible LifeLine subscribers or daily transmission of the eligibility information directly from the opt-out state administrators. In the ACP Order, the Commission should require USAC to accept either real-time API access to state administrators or accept daily files from either an ETC or the state administrator. The Bureau should require nondiscriminatory approval of AVPs for Lifeline ETCs to remove this artificial and prejudicial impediment to ACP enrollment in California, Oregon, and Texas.

See the official press release here.