All posts tagged: NPRM

NARUC Discusses Lifeline NPRM’s Proposal

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.

 

 

 

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admin1NARUC Discusses Lifeline NPRM’s Proposal
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CTIA Opposes FCC Lifeline Changes Banning Wireless Resellers

February 21, 2018 –  CTIA, an wireless connectivity advocacy organization, voices their opposition to the recent FCC proposals on the Lifeline Program, which provides essential communication services to qualifying low-income American families. CTIA’s filed their comments to the FCC in response to the FCC’s 2017 Notice of Proposed Rulemaking (NPRM) and Notice of Inquiry (NOI), and more specifically comments on concerns over the proposed elimination of wireless resellers from the Lifeline Program, which would ban non-facilities-based providers from serving as Lifeline Providers.

CTIA on Elimination of Wireless Resellers from Lifeline Program

CTIA’s belief that the Commission’s proposal elimination of wireless resellers from Lifeline would negatively impact competition and harm low-income consumers supports the integrity of the Lifeline program and urges the FCC to reconsider these key issues. CTIA expressed that while it supports the FCC’s commitment ensure the integrity of the Lifeline Program. However, in the letter they stated that “expeditious implementation of the National Lifeline Eligibility Verifier (National Verifier or Verifier) is the most important thing the Commission can do to limit waste, fraud, and abuse in the Lifeline program. Accordingly, the Commission should remain focused on implementing the National Verifier before considering any further large-scale program reforms” and that the organization “strongly encourages the Commission not to adopt the proposal in the NPRM/NOI to exclude non-facilities-based providers from the Lifeline program.”

CTIA to FCC on “Exhibit A” Lifeline Economic Study

Also referenced in the letter from CTIA was the “Exhibit A” Declaration by Dr. John Mayo, an recently conducted economic study which also supports of not excluding resellers (non-facilities-based providers) from Lifeline. This study provides evidence that the NPRM’s proposal to limit Lifeline facilities-based carriers is inconsistent with economic basis of Lifeline and doesn’t support the goal of universal connectivity.  CTIA concludes “Ultimately, Dr. Mayo’s analysis shows that the data on network investment do not support limiting subsidies to facilities-based providers and excluding non-facilities based providers in order to further incent deployment.  In light of the economic evidence, the Commission should conclude that, in order to avoid undermining investment in broadband networks, it must continue to allow non-facilities based providers to participate in Lifeline.”

Read Complete Filing of CTIA Comments to FCC

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2018/03/180221-CTIA-Lifeline-Comments.pdf”]

 

 

 

About CTIA:

CTIA® represents the U.S. wireless communications industry and the companies throughout the mobile ecosystem that enable Americans to lead a 21st century connected life. The association’s members include wireless carriers, device manufacturers, suppliers as well as apps and content companies. CTIA vigorously advocates at all levels of government for policies that foster continued wireless innovation and investment. The association also coordinates the industry’s voluntary best practices, hosts educational events that promote the wireless industry and co-produces the industry’s leading wireless tradeshow. CTIA was founded in 1984 and is based in Washington, D.C.

About NaLA:

The National Lifeline Association is the only industry trade group specifically focused on the Lifeline segment of telecommunications. We support the 4 essential components of Lifeline: ETCs & Providers, Distributors, Lifeline Supporters & Participants, and Government & Regulatory Bodies. We are passionate about the continuity and advancement of the Lifeline program and we drive this vision through our mission to “support providers, distributors, participants, and supporters of lifeline through education, cooperation, and advocacy.”

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Lee SchaferCTIA Opposes FCC Lifeline Changes Banning Wireless Resellers
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Sprint Opposes Lifeline Wireless Reseller Ban

February 20, 2018 — Sprint expresses concerns with the FCC’s recent proposals concerning a Lifeline wireless reseller ban, which would prohibit wireless resellers from serving low income households as Service Providers through the Lifeline Program. The Notice on Proposed Rulemaking (NPRM), an initiative from the FCC’s November 2017 Open Meeting that included various Lifeline Program initiatives, such as banning wireless resellers from providing Lifeline service.

Sprint says Lifeline Wireless Reseller Ban Could Affect 6.1 Million

Sprint, a facilities-based provider, has echoed the concerns of various non-facilities-based providers on the recent FCC proposals found in the NPRM. They oppose the Lifeline wireless reseller ban that the FCC is pursuing, and state that the “elimination of resellers from the Lifeline program would be disruptive to current and potential Lifeline customers. The majority of Lifeline customers obtain service from resellers, which had an estimated 6.1 million customers as of December 2017.”

Consequences of FCC Lifeline Wireless Reseller Ban

The letter from Sprint highlights many concerns for Lifeline Participants that rely on the program to assist them in accessing essential communication services. They noted that the Lifeline wireless reseller ban would result in a “a sharp reduction in the number of wireless service providers offering Lifeline service; in some areas, there may remain only a single facilities-based wireless Lifeline service provider, and in other areas, there may be no facilities-based wireless Lifeline service provider at all.” Sprint adds that “users [Lifeline Participants] will not realize they need to obtain service from a facilities-based carrier, some will not know how to transfer their service, some will not provide required documentation in a timely manner. Some customers will successfully transfer to a facilities-based carrier, but some will lose service altogether.”

The forced exit of wireless resellers as Lifeline service providers from the Lifeline market is disruptive of consumer access to emergency services, or other resources necessary for employment, health care, or childcare.

Read Sprint’s Letter to FCC

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2018/02/Sprint-LL-comments.pdf”]

Postponing of Lifeline Program Eligibility Verifier (National Verifier)

In addition to concerns about the ban of wireless resellers in Lifeline, Sprint also asserts in the letter to the FCC that the National Verifier is a crucial part of reducing waste, fraud, and abuse within the program – and should be the most important focus of the Commission at this time.

The recent postponing of the National Verifier launch has created concern that the Commission’s actions do not support it’s stated goals about strengthening the Lifeline Program eligibility verification processes.

“Getting the deployment timeline back on track is the surest way for the Commission to advance the common goal of ensuring Lifeline program integrity,” Sprint states in their letter to the FCC. Sprint, TracFone and other Telecommunication companies are in agreement that efforts are best focused on the National Verifier, prior to making any drastic changes to the program, which helps nearly 11 million low-income Americans access phone and internet services.

 

About NaLA:

The National Lifeline Association is the only industry trade group specifically focused on the Lifeline segment of telecommunications. We support the 4 essential components of Lifeline: ETCs & Providers, Distributors, Lifeline Supporters & Participants, and Government & Regulatory Bodies. We are passionate about the continuity and advancement of the Lifeline program and we drive this vision through our mission to “support providers, distributors, participants, and supporters of lifeline through education, cooperation, and advocacy.”

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Lee SchaferSprint Opposes Lifeline Wireless Reseller Ban
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56 Congress Members Sign Letter To FCC Opposing November 16 Lifeline Program Changes

KENNETT SQUARE, PA–(Marketwired – Nov 16, 2017) The National Lifeline Association (Referred to as “NaLA”) reports that 56 members of Congress have signed and delivered a letter to FCC Chairman Ajit Pai opposing changes to the Lifeline Program which attack low-income families, Veterans, and Native American Tribes.

Press-Release-56-House-Democrats-Sign-Congressional-Lifeline-Letter-to-FCC-on-Lifeline-Changes

The Lifeline Program was created 30 years ago by President Reagan to help ensure that the most vulnerable Americans – which include low-income families, Veterans, and Native Americans – have access to lifesaving communications services. The program was updated and reformed under Presidents George W. Bush and Barack Obama to accommodate for technological advances and to strengthen the program’s integrity by minimizing fraud, waste, and abuse.

The program currently provides a modest monthly subsidy of $9.25 from Universal Service Funds, to connect low-income Americans with telephone and internet services.

Proposed changes by the FCC to the Lifeline Program include:

  • Major cuts and budget caps on the Lifeline program, which may shrink the size of all recipient benefits
  • Lifetime cap on individual users which could inflict arbitrary limits on participation and completely cut off those in need
  • Ban “non-facilities-based providers” from participating in the Lifeline Program

The following statement may be attributed to David Dorwart, Chairman of NaLA. “By banning ‘non-facilities-based providers’ from participating in the Lifeline program, 80% of the top Lifeline providers will be forced to stop service, resulting in disconnections for approximately 7.5 million Lifeline recipients nationwide. In some areas of the country, these are the only providers that offer Lifeline service. As a result, as many as three quarters of the current Lifeline subscriber base will be stripped of this crucial service, including over 1.3 million active and retired Veterans and more than half of all current Tribal Lifeline subscribers.”

If ultimately adopted, Chairman Pai’s proposals would roll back the United States’ longstanding commitment that advanced telecommunications services should be universally available to and affordable for all Americans. According to Public Knowledge, “The Chairman’s plan would strand millions of low-income families, Veterans, and children without affordable communications services, and drastically curtail their access to the education, job training, and basic services that increasingly require an internet connection. Rather than moving forward with this plan that would harm the most vulnerable, the FCC should refocus its efforts to promote affordable, competitive broadband for all Americans, and ensure that the Lifeline program remains a core component of our efforts to close the digital divide.”

Read the Congressional letter in its entirety:

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2017/11/final_Meeks-Moore-Lifeline-Letter.pdf”]


Congressman Gregory W. Meeks, stated,
“In our modern, highly technological and interconnected world, internet and phone service are all but required to lead a functional life. Many Americans still don’t have phone and internet access, rendering it nearly impossible to complete everyday tasks, such as finishing assigned schoolwork or conducting a phone interview. He also stated, “The digital divide—which Chairman Pai promised he would seek to minimize—persists today and the Lifeline Program is critical in helping minimize it. Yet, Chairman Pai’s proposed changes would practically decimate the Lifeline program, upon which millions of Americans rely. Indeed, this is nothing more than a poorly disguised attack on our nation’s most vulnerable citizens. I thank Congresswoman Moore and the cosigners and endorsing organizations of this letter for partnering with me to stand against Chairman Pai’s efforts to widen the digital divide.”

Organizations endorsing the congressional letter opposing changes to the Lifeline Program include: National Lifeline Association (NaLA), National Association for the Advancement of Colored People (NAACP), Communications Workers of America (CWA), Public Knowledge, Free Press, National Hispanic Media Coalition, Benton Foundation, Greenlining Institute, United Church of Christ, Common Sense Kids Action, National Consumer Law Center, The Utility Reform Network, OpenMedia, OCA- Asian Pacific American Advocates, New America’s Open Technology Institute, Appalshop, Inc.

The National Lifeline Association (NaLA) takes the position that these proposed changes will widen the digital divide facing low-income Americans and are unnecessary given successful reforms to the Lifeline Program, including the December 2017 launch of the National Verifier. Because Lifeline accounts for less than 20% of the allocations to the Universal Service Fund (source: 2016 USAC Annual Budget) and is currently running at about $1 billion a year below its budget, steps aimed at reducing the program’s budget, participation levels and disbursements are indefensible.

About The National Lifeline Association (NaLA):

The National Lifeline Association is the only industry trade group specifically focused on the Lifeline segment of telecommunications. We support the 4 essential components of Lifeline: ETCs & Providers, Distributors, Lifeline Supporters & Participants, and Government & Regulatory Bodies. We are passionate about the continuity and advancement of the Lifeline program and we drive this vision through our mission to “support providers, distributors, participants, and supporters of lifeline through education, cooperation, and advocacy.”

NaLA’s Vision: “In America, every person should have access to essential communication services.”

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Lee Schafer56 Congress Members Sign Letter To FCC Opposing November 16 Lifeline Program Changes
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Free Press Opposes FCC Lifeline Rulings, “A Direct Attack” on Low-Income Americans

Free Press opposes FCC Lifeline Rulings that will affect the Lifeline Program, a program that connects low-income Americans to crucial communications services. The proposed changes were released October 26th in a draft by Chairman Pai and the current FCC administration to be a part of the November 16 Open Meeting agenda and would greatly eliminate the access to service for many low-income families in the United States.

Free Press Opposes FCC Lifeline Rulings that Limit Lifeline Funds to Facilities-Based Providers

Free Press has addressed their opposition to the rulings, including their major concern with the proposal to limit funds to “facilities-based” providers, which will eliminate Lifeline resellers (also known as ETCs) from providing Lifeline service.

Free Press Policy Director, Matthew Wood, urges the FCC to reconsider, asserting that “..eliminating resale carriers [Lifeline resellers] from Lifeline would eliminate participation by providers currently serving no less than two-thirds or even three ­quarters of the current Lifeline subscriber base. Chairman Pai’s war on carriers that actually make robust use of the fund is of course a direct attack on the intended beneficiaries of the program: low-income individuals and families, all too often from traditionally under-served groups such as people of color, immigrants, veterans, and the elderly.”

Read More from Free Press on FCC Lifeline Rulings

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2017/11/FreePress-Ex-Parte-Letter-to-FCC-on-Lifeline-Changes-Eliinating-Resellers-1.pdf”]

About Free Press

Free Press is an independent organization that believes that change happens when people have a real voice in the political process; they seek to mobilize their growing base of 900,000 activists to sign petitions, meet with their elected officials, attend rallies and town-hall meetings, write letters to the editor, and take part in other targeted actions. Additionally, the organization crafts policy proposals, conducts research, testifies before Congress and fights in court for policies that serve the public interest.

Support Lifeline Program or Read More on FCC Changes

NaLA appreciates contributions from Lifeline Advocates; donate now to assure the continuation of the Lifeline Program or read more on the FCC’s proposed changes.

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Lee SchaferFree Press Opposes FCC Lifeline Rulings, “A Direct Attack” on Low-Income Americans
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Cherokee Tribal Organization ‘Stongly Opposes’ FCC Lifeline Changes

November 9 — In light of the FCC’s proposed changes to the Lifeline Program, there have been responses from several Native American Tribal Organizations, including Oklahoma’s Cherokee Nation, the United States’ largest federally-recognized tribe. Cherokee Nation Principal Chief, Bill Baker wrote the FCC to express strong opposition to the proposed changes that will be up for ruling at the FCC’s November 16 Open Meeting.

FCC Proposed Changes Affecting Tribal Members

The Fourth Report and Order, Order on Reconsideration, Memorandum Opinion and Order, Notice of Proposed Rulemaking, and Notice of Inquiry (WC Docket Number 17-287, WC Docket Number 11-42, and WC Docket Number 09-197), is an imminent threat to 35,000+ Tribal members living in Oklahoma.

Baker responds with concern for the impact these rulings will have on Tribal Members who are eligible for Tribal Lifeline Support, stating “Limiting access to the enhanced Tribal Lifeline subsidy based on population density ignores the uniqueness of each tribal nation and expressly ignores one of the goals of the program. Cherokee Nation spans across 14 unique counties that have both extremely rural areas, as well as urban centers. Although accessibility issues may vary, affordability is a constant struggle for our tribal citizens. One of the areas targeted for elimination under this proposed rule would include Tulsa, Oklahoma, which is home to more than 37,000 Cherokee Nation citizens. Living in an area with a population over 25,000 people does not determine one’s ability to afford phone services.”

Lifeline Letter from Cherokee Nation

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2017/11/Cherokee-FCC-Lifeline-Letter_11.8.17.pdf”]

About Cherokee Nation

“Cherokee Nation is the largest federally recognized Indian tribe in the United States with almost 360,000 citizens and a tribal jurisdiction that spans 7,000 square miles in northeast Oklahoma. Cherokee Nation is committed to the social and economic success of our citizens and provides services such as health care, housing, childcare, career placement and a variety of other key programs to support our most vulnerable populations.”  – Bill John Baker, Cherokee Nation Principal Chief 

Support Lifeline Program or Read More on FCC Changes

NaLA appreciates contributions; donate now to assure the continuation of the Lifeline Program or read more on the FCC’s proposed changes.

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Lee SchaferCherokee Tribal Organization ‘Stongly Opposes’ FCC Lifeline Changes
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Lifeline Advocates Urge FCC to Reconsider Proposed Program Changes

On October 26th, the FCC published the upcoming November 16 public meeting agenda, which calls for some significant changes to the Lifeline Program, which provides affordable communication services to low-income Americans.  Advocates of the Lifeline Program are now voicing their concerns about some of the proposed rules, which will mainly aim to:

  • Direct Lifeline Funds & Enhanced Lifeline Support to Facilities-based Providers
  • Adopt a Self-enforcing Budget Cap
  • End States’ Role in Designating ETCs
  • Redefine Tribal Lands as Rural
  • Eliminate LBP Designations

Responses to FCC Proposals for Lifeline Program

Advocates of both the Lifeline Program and the FCC’s commitment to “bridge the digital divide” have expressed concern over many of the potential changes, and are seeking FCC reconsideration.

CTIA, an organization that represents the U.S. wireless communications industry (and the companies throughout the mobile ecosystem) that enable Americans to lead a 21st century connected life, voiced some of their concerns in a letter to Chairman Pai, yesterday:

“While CTIA remains committed to working with the Commission to strengthen the Lifeline program’s administration, some of the changes proposed in the draft Lifeline item would negatively impact millions of low-income consumers who rely on wireless supported Lifeline services. As the Commission moves forward an agenda designed to close the digital divide, CTIA urges the Commission to recognize that Lifeline, especially wireless Lifeline, remains a critical tool that enables low-income consumers to access 21st Century occupational, educational, health and public safety communications.”

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2017/11/CTIA-Lifeline-FCC-NPRM-NOI-Response-Letter-11082017.pdf”]

 

Additionally, NaLA has activated a task force of highly qualified industry experts and advocates, who are working hard to ensure the continuity of the Lifeline Program. This task force is charged with handling the outreach, communication, collaboration, and education required to inform lawmakers and constituents aware of the proposed changes and what they can do to support the program and protect the Lifeline Program participants.

NaLA Member and Lifeline Advocate Support

Our members and supporters have already begun efforts to protect the low-income Americans who participate in the Lifeline Program. Access to telecommunications services provided by this program connect low-income Americans with emergency services, employment, education, childcare, and healthcare.

NaLA appreciates its members contributions to this cause; donate now to assure the continuation of the Lifeline Program or read more on the FCC’s proposed changes.

About CTIA

CTIA vigorously advocates at all levels of government for policies that foster continued wireless innovation and investment. CTIA also coordinates the industry’s voluntary efforts to provide consumers with a variety of choices and information regarding their wireless products and services. CTIA also hosts educational events that promote the wireless industry and coordinates the industry’s efforts to provide consumers with a variety of choices and information regarding their wireless products and services as well as the industry’s voluntary best practices.

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Lee SchaferLifeline Advocates Urge FCC to Reconsider Proposed Program Changes
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Colville Tribe Responds to FCC Plans for Tribal Lifeline Funds

November 7, 2017 — The Confederated Tribes of the Colville Reservation (CTCR) sent a response to the FCC, regarding recent changes that will soon be decided regarding the Lifeline Program changes, specifically the proposal to limit Tribal Lifeline Funds (and eventually all Lifeline funds) to facilities-based providers.

Dr. Michael E. Marchand, Chairman of the CTCR, writes “We [the CTCR] are especially disconcerted with the FCC’s proposal to eliminate resellers from the Tribal Lifeline program. Wireless resellers offering enhanced Tribal Lifeline service generate revenue for the Tier 1 service providers that can be invested to expand wireless infrastructure on Tribal lands, a crucial need for the Colville Tribes. Wireless resellers have developed specialized business models to connect with residents of our Reservation; resellers currently provide critically-needed Lifeline service to many low-income individuals on the Colville Reservation. If these companies are no longer permitted to provide Tribal Lifeline service, it will be difficult, and in many cases impossible, for members of the Colville Tribes to obtain affordable voice and broadband services.”

View Colville Indian Reservation Letter to FCC

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2017/11/Colville-Confederated-Tribes-Lifeline-Ex-Parte.11.7.17.pdf”]

About the Confederated Tribes of the Colville Reservation

The Confederated Tribes of the Colville Reservation is an organization that was formed in 1972 to represent the Colville Tribes, and is federally-recognized in the United States. The governing body, the Colville Business Council, state their mission for the Reservation is to “establish policies which would improve the economic condition of the Confederated Tribes, its members and posterity, with emphasis toward the most efficient and effective development, preservation, and protection of the resources available, including human and renewable natural resources, resulting in minimum negative impacts upon the culture and traditions of enrolled members of the Colville Confederated Tribes” (Source: CTCR Website)

Support Lifeline Program or Read More on FCC Changes

NaLA appreciates contributions; donate now to assure the continuation of the Lifeline Program or read more on the FCC’s proposed changes.

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Lee SchaferColville Tribe Responds to FCC Plans for Tribal Lifeline Funds
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