John Heitmann

The National Lifeline Association (NaLA) submitted a petition to the Federal Communications Commission requesting that the FCC temporarily waive the Lifeline reimbursement amounts in the Commission’s rules until Congress allocates additional funding for the Affordable Connectivity Program (ACP) or passes broader legislation to reform the Universal Service Fund (USF) and pay for the ACP in an alternative manner.

Congress and the Federal Communications Commission must act swiftly and purposefully to ensure that low-income households continue to have sustainably affordable access to communications services through a fully funded low-income program that is structured to effectively close the affordability component of the digital divide while preserving program integrity. National Lifeline Association (NaLA) offers the following recommendations and observations:

For years, the Federal Communications Commission has administered the Universal Service Fund (USF), overseeing four programs designed to bring connectivity to rural areas, to target institutions like schools, libraries and healthcare facilities and to low-income consumers. Temporary COVID-19 connectivity programs appear to have presaged a shift from the FCC defining universal service programs to Congress appropriating funding and directing the future of universal service, all the while shifting the primary administrator of the funding.

On October 4, 2021, the National Lifeline Association (NaLA) met with the Office of Acting Federal Communications Commission Chairwoman Rosenworcel to discuss the Lifeline Program and the Emergency Broadband Benefit (EBB) Program. The discussion focused on the Lifeline minimum service standards (MSS), getting the Lifeline program ready for the end of the EBB and certain Lifeline and EBB process improvements that should be made by the Universal Service Administrative Company (USAC).

The National Lifeline Association urged the Federal Communications Commission to expeditiously release a Public Notice seeking comment on the association's Petition for Rulemaking so that others can comment on it and the FCC can build a record to take the necessary actions to transition the Lifeline program into a program that is post-Emergency Broadband Benefit Program ready. The FCC should not work in a linear fashion, but rather consider important improvements to the Lifeline program now so that those improvements can be in place when the Emergency Broadband Benefit Program funding runs

The Lifeline Connects Coalition met with Federal Communications Commission Chairman Ajit Pai’s Wireline Legal Advisor, Dr Jay Schwarz, on May 11, 2017, to discuss the draft Open Internet NPRM and the Commission’s commitment to support broadband services through the Lifeline program. It also discussed the upcoming increase in the Lifeline minimum service standards and current barriers to entry and industry consolidation in the Lifeline program.

The Lifeline Connects Coalition filed a Petition on October 25, 2016 seeking a waiver of certain new Lifeline rules. The coalition asked the Federal Communications Commission’s Wireline Competition Bureau to waive changes which replace a current 60-day non-usage period with 30 days because the new 30-day non-usage rules will harm and endanger consumers. The coalition also asked the Bureau to direct the Universal Service Administrative Company (USAC) to rescind its guidance that would implement the 30-day non-usage rule prior to the December 2, 2016 effective date, arguing it is unlawful and impractical for eligible telecommunications carriers (ETCs) to administer.

The Lifeline Connects Coalition met with legal advisors to Federal Communications Commission Chairman Tom Wheeler and fellow-FCC Commissioners Mignon Clyburn and Jessica Rosenworcel and FCC Wireline Competition Bureau staff on June 28, 2016, to discuss its Petition for Reconsideration of the Lifeline Reform Order.

The coalition seeks reconsideration of: the mobile broadband minimum service standards after December 1, 2017; issues related to the National Verifier; and the decision not to provide streamlined ETC application processing for voice-only Lifeline services. The coalition also seeks clarification of the rolling recertification rule. The coalition also discussed potential for confusion regarding the use of FCC and Universal Service Administrative Company (USAC)-established dispute resolution processes for Third Party Identity Verification, applicant addresses, and the Independent Economic Household worksheet and process established to implement the FCC’s one-per-household rule.